SECTION 6. DRAFTING

INFORMATION

The principal author of this revenue procedure is Brenda D. Wilson of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Wilson at (202) 622–4800 (not a toll-free call).

ing into account any net positive § 481(a) adjustment over four taxable years, the partnership must take into account one-half of any net positive § 481(a) adjustment in its 2008 taxable year and one-fourth in each of its next two taxable years.

.04 Submitting a request for a revised year of change . A request to revise the year of change for a Form 3115 pending in the national office should include the name of the filer (and each applicant, if applicable) on the Form 3115, the national office reference number (for example, CAM–123456–07), the name of the national office contact person for the Form 3115 (if known), the due date (without extension) for the filer’s federal income tax return for the year of change, and a statement agreeing to the applicable requirements in section 12.01(3) of this revenue procedure. The request must be accompanied by the penalties of perjury statement in section 9.08(3) of Rev. Proc. 2007–1 (or successor) and should be submitted to the applicable address in section 9.08(6) of Rev. Proc. 2007–1 (or successor). Alternatively, the request may be faxed to a fax number provided by the national office contact person for the Form 3115. If faxed, a copy of the request and an original signed penalties of perjury statement must also be mailed or delivered to the applica

ble address in section 9.08(6) of Rev. Proc. 2007–1 (or successor). .05 Notification of approval or denial . The national office will notify the taxpayer, orally and later in writing, of the approval or denial of the taxpayer’s request to revise the year of change for a pending Form 3115.

.06 Service’s discretion to deny a re- quest . The Service reserves the right to deny a taxpayer’s request for a revised year of change for a pending Form 3115 in any situation in which the Service determines it would not be in the best interest of sound tax administration to allow the taxpayer to revise the year of change. A taxpayer is not entitled to a conference with the Service if the request to revise the year of change for a pending Form 3115 is denied.