SECTION 6. PROCEDURES FOR

ELECTING FOUR-YEAR SPREAD PERIOD

A partner or S corporation shareholder within the scope of this revenue procedure that wants to elect to spread income ratably over a four-year period under this revenue procedure must make the election by:

(1) recording the appropriate ratable income amount ( i.e., one quarter of its share of income) on either:

(a) a timely filed original federal income tax return for the taxable year of the partner or S corporation shareholder with or within which the partnership’s or S corporation’s short taxable year ends; or

(b) in the case of a partner or S corporation shareholder within the scope of this revenue procedure that wants to make the four-year spread period election, but prior to November 24, 2003, has timely filed a federal income tax return for the taxable year with or within which the partnership’s or S corporation’s short taxable year ends, on an appropriate amended federal income tax return that is filed on or before April 12, 2004; and (2) attaching to the original or amended federal income tax return for the taxable year with or within which the partnership’s or S corporation’s short taxable year ends, and to the federal income tax returns for every other taxable year of the spread period, a completed Form 8082, Notice of Inconsistent Treatment or Administrative Adjustment Request, containing an explanation in Part III similar to the following: “Election under Rev. Proc. 2003–79 to apply a ratable 4-year spread of the share of income attributable to a change in annual accounting period.”