SECTION 8. QPCLAS ENTERED

INTO PRIOR TO THIS REVENUE PROCEDURE

Use of the Net Consideration Method described in section 5 of this revenue procedure for a QPCLA entered into prior to February 14, 2007 will not be raised as an issue by the IRS. If a taxpayer uses the Net Consideration Method described in section 5 of this revenue procedure for one or more QPCLAs entered into prior to February 14, 2007, and its use of that method is an issue under consideration (within the meaning of section 3.09 of Rev. Proc. 2002–9, 2002–1 C.B. 327, or its successor) in examination, in appeals, or before the U.S.

Tax Court, that issue will not be further pursued by the IRS.