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Introduction

SECTION 6. ADOPTION OF SAFE

Internal Revenue Bulletin 2007-21 · 2026-10-03 edition · updated 2026-10-04 · United States

HARBOR METHOD OF ACCOUNTING

.01 Any change to the safe harbor method provided in SECTION 4 of this revenue procedure is a change in method of accounting to which the provisions of section 446 and section 481, and the regulations thereunder, apply. Under § 1.446–1(e)(2)(i), a taxpayer generally must secure the consent of the Commissioner before changing a method of accounting for federal income tax purposes. Section 1.446–1(e)(3)(ii) authorizes the Commissioner to prescribe administrative procedures setting forth the terms and conditions necessary to obtain consent to change a method of accounting.

.02 If a bank with less than 6 years of collection experience wants to change its method of accounting for uncollected interest to the safe harbor method provided in SECTION 4 of this revenue procedure, the bank is required to follow the provisions of Rev. Proc. 97–27, 1997–1 C.B. 680 (or its successor), as modified and amplified by Rev. Proc. 2002–19, as amplified and clarified by Rev. Proc. 2002–54, except that the scope limitations in section

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▸Contents — Internal Revenue Bulletin 2007-21

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