SECTION 1. PURPOSE

This revenue procedure modifies Rev. Proc. 97–27, 1997–1 C.B. 680, as modified and amplified by Rev. Proc. 2002–19, 2002–1 C.B. 696, as amplified and clarified by Rev. Proc. 2002–54, 2002–2 C.B. 432, which provides the general procedures for obtaining the advance consent of the Commissioner of Internal Revenue

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able year under section 5.02(3)(a) of this revenue procedure had the taxpayer not revised the year of change (for example, if the year of change is revised to the first succeeding taxable year, the taxpayer must agree to take into account one-half of any net positive § 481(a) adjustment in the revised year of change and one-fourth in each of its next two taxable years); and

(b) The taxpayer must agree to provide the § 481(a) adjustment (positive or negative) for the revised year of change within 21 calendar days (or a longer period if agreed to by the national office) after the Service first notifies the taxpayer that its request to revise the year of change is approved.

.02 Multiple applicants on one Form 3115. If the Form 3115 is for an identical change in accounting method for more than one applicant, the taxpayer must request to revise the year of change for all applicants to which the Form 3115 relates.

.03 Compelling circumstances . (1) In general . In the case of a taxpayer that does not meet the condition in section 12.01(1) of this revenue procedure, a taxpayer with compelling circumstances may request to revise the year of change for the Form 3115, in lieu of submitting a new Form 3115 for the proposed revised year of change. The taxpayer must demonstrate those compelling circumstances. An example of compelling circumstances would include the following.

(2) Example. A calendar year partnership with 50 individual partners timely files a Form 3115 under Rev. Proc. 97–27 for a change in method of accounting for its 2007 taxable year. The partnership’s Form 1065, U.S. Return of Partnership Income, and Schedules K–1, Partner’s Share of Income, De- ductions, Credits, etc., and the partners’ Forms 1040, U.S. Individual Income Tax Return, for the requested year of change are all due April 15, 2008. On March 17, 2008, the partnership submits a request to revise the year of change for its pending Form 3115 to its 2008 taxable year because the partnership’s Form 3115 is pending in the national office. Because the Form 3115 is pending in the national office 30 days prior to the due date of the partners’ Forms 1040, the partnership will be unable to provide timely Schedules K–1 that take into account the proposed accounting method change before the partners prepare and file their 2007 Forms 1040. Therefore, to avoid the potential for the 50 partners to be required to file amended 2007 Forms 1040 to take into account the partnership’s requested change in method of accounting for the 2007 taxable year, once approved, the Service will ordinarily allow the partnership to revise the year of change for its Form 3115 to its 2008 taxable year. If the accounting method change is approved for the partnership’s 2008 taxable year, in lieu of tak

to change a method of accounting. This revenue procedure allows taxpayers, under certain conditions, to request to revise the year of change for a Form 3115, Appli- cation for Change in Accounting Method, that is pending in the national office, and modifies the period for taking into account a net positive adjustment under § 481(a) of the Internal Revenue Code when the Commissioner approves the taxpayer’s request to revise the year of change.