Section 451.—General Rule for Taxable Year of Inclusion

This revenue procedure amplifies Revenue Procedure 2005–3, 2005–1 I.R.B. 118, which sets forth areas of the Internal Revenue Code in which the Internal Revenue Service will not issue advance rulings or determination letters, by providing that the Internal Revenue Service will not issue advance rulings or determination letters involving the recovery of costs by any investor owned public utility through a leg

islatively authorized securitization mechanism. See Rev. Proc. 2005-61, page 507.

This revenue procedure amplifies Revenue Procedure 2002–49, 2002–2 C.B. 172, by extending the safe harbor provisions for certain investor-owned utility companies to recover transition costs through a legislatively authorized securitization mechanism, to any utility company for the recovery of specified costs other than transition costs through such legislatively authorized securitization mechanisms. Additionally, this revenue procedure clarifies that payments of principal and interest with respect to evidences of indebtedness in a utility’s securitization transaction for the recovery of transition or specified costs are not required to be exactly level. See Rev. Proc. 2005-62, page 507.