SECTION 4. ALLOCATIONS FOR

BUILDINGS PLACED IN SERVICE IN THE ALLOCATION YEAR

.01 Time for making a commercial re- vitalization expenditure allocation . Except as provided in sections 5 and 6 of this revenue procedure, a commercial revitalization expenditure allocation to a qualified revitalization building must be made in the calendar year in which that building is placed in service by the taxpayer.

.02 Manner for making a commercial re- vitalization expenditure allocation .

(1) In general . A commercial revitalization expenditure allocation is made for a qualified revitalization building when an allocation document containing the information described in section 4.02(2) of this revenue procedure is completed, signed, and dated by an authorized official of the commercial revitalization agency. The agency must send a copy of the allocation document to the taxpayer receiving the allocation no later than 60 calendar days following the close of the calendar year in which the allocation is made. Neither the original nor a copy of the allocation document is to be sent to the Service.

(2) Information required in the alloca- tion document . The allocation document must include:

(a) The name, address, and taxpayer identification number of the commercial revitalization agency making the commercial revitalization expenditure allocation;

(b) The name, address, and taxpayer identification number of the taxpayer receiving the allocation;

(c) The address of the qualified revitalization building, or if none exists, a specific description of the location of each building;

(d) The date of the allocation of the commercial revitalization expenditure amount;

(e) The commercial revitalization expenditure amount allocated to the qualified revitalization building on that date; and

(f) A certification under penalties of perjury by an authorized official of the commercial revitalization agency that the official has examined the information in the allocation document, and, to the best of the official’s knowledge and belief, this information is true, correct, and complete.

2003–24 I.R.B. 1018 June 16, 2003

duction election for the qualified revitalization building as provided in section 7.02(1) or 7.02(2)(a) of this revenue procedure but wants to do so must file a request for an extension of time to make the election under the rules in § 301.9100–3.

.03 Scope of the Election . If a taxpayer placed in service more than one qualified revitalization building during a taxable year, the taxpayer may make the commercial revitalization deduction election for the placed-in-service year separately for each building as provided in section 7.02 of this revenue procedure. For example, a taxpayer that places in service in 2003 three qualified revitalization buildings for which commercial revitalization expenditure amounts are allocated, may elect to deduct one-half of the qualified revitalization expenditures for one building and elect to amortize the qualified revitalization expenditures for the other two buildings ratably over a 120-month period.

.04 Revocation . The commercial revitalization deduction election is revocable only with the prior written consent of the Commissioner of Internal Revenue. To seek the Commissioner’s consent, the taxpayer must submit a request for a letter ruling in accordance with the provisions of Rev. Proc. 2003–1, 2003–1 I.R.B. 1 (or its successor).

.05 Failure to make commercial revi- talization deduction election . If a taxpayer does not make the commercial revitalization deduction election for a qualified revitalization building within the time and in the manner prescribed in section 7.02 of this revenue procedure, the amount of depreciation allowable for that property must be determined under § 168 for the placed-inservice year and for all subsequent years. Thus, the commercial revitalization deduction election cannot be made by the taxpayer in any manner other than as set forth in section 7.02 of this revenue procedure (for example, through a request under § 446(e) to change the taxpayer’s method of accounting).