SECTION 3. SCOPE

.01 This revenue procedure applies to a taxpayer that wants to make one or more of the following changes or adoptions:

(1) Change to a safe harbor NAE method provided in § 1.448–2(f)(1) (the revenue-based moving average method), (f)(2) (the actual experience method), (f)(3) (the modified Black Motor method), (f)(4) (the modified moving average method), or (f)(5) (the alternative nonaccrual-experience method);

(2) Change to a periodic system (for further guidance, see, for example, Notice 88–51, 1988–1 C.B. 535); (3) Change from a NAE method to a specific charge-off method;

(4) Change from a sub-method of its current NAE method provided in § 1.448–2 regarding applicable periods to another sub-method regarding applicable

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order to adopt a method of accounting for the first time. However, a taxpayer within the scope of section 3.01(8) of this revenue procedure must obtain advance consent of the Commissioner in order to adopt a NAE method other than a safe harbor method provided in § 1.448–2(f)(1) through (5). In order to obtain advance consent, a taxpayer must follow the procedures for a change in method of accounting. Specifically, a taxpayer must file a Form 3115 and must comply with the following provisions of Rev. Proc. 97–27:

(a) Section 3, Definitions; (b) Section 5, Procedures for Taxpayers not under Examination;

(c) Section 8, General Application Procedures;

(d) Section 10, Effect of Consent; and (e) Section 11, Review by District Director.

(2) Year of change . The year in which the taxpayer adopts the NAE method under this section 4.03 is treated as the “year of change” for purposes of the rules, filing deadlines, and procedures under Rev. Proc. 97–27.