SECTION 1. PURPOSE

In general, the Internal Revenue Service will follow Westpac Pacific Food v. Commissioner, 451 F.3d 970 (9 ^th Cir. 2006), with respect to taxpayers that adopt the Advance Trade Discount Method of accounting described in section 4 of this

revenue procedure. Accordingly, this revenue procedure permits accrual method taxpayers described in section 3 of this revenue procedure to account for advance trade discounts under the Advance Trade Discount Method. This revenue procedure also provides procedures to obtain the automatic consent of the Commissioner to change to the Advance Trade Discount Method.