SECTION 1. PURPOSE

This revenue procedure supersedes Rev. Proc. 83–77, 1983–2 C.B. 594, and the 90-day extension of time granted therein for submitting applications or requests for consent to change a method of accounting under § 1.77–1, 1.381(c)(4)–1(d)(2), 1.381(c)(5)–1(d)(2), 1.455–6(b), 1.456–6(b), or 1.461–1(c)(3)(ii) of the Income Tax Regulations.

An application or request submitted in accordance with this revenue procedure for consent to change a method of accounting under § 1.77–1, 1.455–6(b), 1.456–6(b), or 1.461–1(c)(3)(ii) may be submitted during the taxable year in which the taxpayer desires to make the change in method of accounting. An application or request submitted in accordance with this revenue procedure for consent to change a method of accounting under § 1.381(c)(4)–1(d)(2) or 1.381(c)(5)–1(d)(2) may be submitted by the later of 1) the last day of the taxable year in which the distribution or transfer occurred, or 2) the earlier of a) the day that is 180 days after the date of distribution or transfer, or b) the day on which the taxpayer files its federal income tax return for the taxable year in which the distribution or transfer occurred.