Rev. Rul. 2004-52 holds that credit card annual
SECTION 4. APPLICATION
Internal Revenue Bulletin 2004-22 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 Subject to subsection .02 of this section 4, if a taxpayer is within the scope of this revenue procedure, the Commissioner will not challenge either the taxpayer’s treatment of credit card late fees as interest or the taxpayer’s treatment of this interest as being part of SRPM and thus as creating or increasing OID on a pool of credit card loans to which these fees relate.
.02 Subsection .01 of section 4 of this revenue procedure applies only if the taxpayer follows all of the requirements of section 5 of this revenue procedure and, if the taxpayer is changing its method of accounting, all of the requirements of section 6 of this revenue procedure.
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