SECTION 4. APPLICATION

.01 Under § 1.446–1(e)(3)(ii), the Commissioner has authority to prescribe the terms and conditions under which taxpayers will be permitted to change their method of accounting. After consideration of the general rules for requesting consent to change a method of accounting under § 1.446–1(e)(3)(i), the requirement to submit applications or requests for consent within the time periods prescribed in the regulations cited in section 3 of this revenue procedure is waived for taxpayers who submit applications or requests for consent in accordance with section 4.02 of this revenue procedure.

.02 Time and manner of application.

(1) An application or request for consent under § 1.77–1, 1.455–6(b), 1.456–6(b), or 1.461–1(c)(3)(ii) that is submitted in accordance with section 4.02(3) of this revenue procedure may be submitted during the taxable year in which the taxpayer desires to make the change in method of accounting.

(2) An application or request under § 1.381(c)(4)–1(d)(2) or 1.381(c)(5)–1(d)(2) that is submitted in accordance with section 4.02(3) of this revenue procedure 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.

(3) The applications or written requests to which this revenue procedure applies are to be filed in accordance with the requirements set forth in § 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), as applicable, except that the taxpayer may file within the time periods provided in section 4.02(1) and (2) of this revenue procedure and send the application or written request to the Internal Revenue Service, Attention: CC:PA:LPD:DRU, P.O. Box 7604, Benjamin Franklin Station, Washington, D.C. 20044. At the top of the application or written request, the taxpayer should either type or legibly print “Filed Under Rev. Proc. 2005–63.”