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Introduction

SECTION 10. REVIEW BY NATIONAL

Internal Revenue Bulletin 2008-36 · 2026-10-03 edition · updated 2026-10-04 · United States

OFFICE

.01 In general . Any application filed under this revenue procedure may be reviewed by the national office. If the application is reviewed by the national office, the procedures in sections 10.02 and 10.03 of this revenue procedure apply.

.02 Incomplete application .

(1) 30-day rule . If the national office reviews an application and determines that the application is not properly completed (see section 6.02(1)(c) of this revenue procedure), or if supplemental information is needed, the national office will notify the taxpayer. The notification will specify the information that the taxpayer needs to provide and permit the taxpayer 30 days from the date of the notification to furnish the information. The national office reserves the right to impose shorter reply periods if subsequent requests for additional information are made. An extension of the 30-day period to furnish information, not to exceed 30 days, may be granted to a taxpayer. A request for an extension of the 30-day period must be made in writing and submitted within the initial 30-day period. If the extension request is denied, there is no right of appeal.

(2) Failure to provide additional infor- mation . Ordinarily, if the taxpayer fails to provide the additional information on a

timely basis, the application does not qualify for the automatic consent procedures of this revenue procedure. If the national office determines that the application does not qualify for the automatic consent procedures of this revenue procedure because the taxpayer has failed to provide the additional information on a timely basis, the national office will notify the taxpayer that consent to make the change in method of accounting is not granted.

.03 National office determination .

(1) Conference in the national office . If the national office tentatively determines that the taxpayer has changed its method of accounting without complying with all the applicable provisions of this revenue procedure (for example, the taxpayer changed to a method of accounting that varies from the applicable accounting method described in this revenue procedure or the taxpayer is outside the scope of this revenue procedure), the national office will notify the taxpayer of its tentative adverse determination and will offer the taxpayer a conference of right, if the taxpayer has requested a conference. For conference procedures for taxpayers other than exempt organizations, see section 10 of Rev. Proc. 2008–1 (or any successor). For conference procedures for exempt organizations, see section 12 of Rev. Proc. 2008–4, 2008–1 I.R.B. 121 (or any successor).

(2) Consent not granted . Except as provided in section 10.03(3) of this revenue procedure, if the national office determines that a taxpayer has changed its method of accounting without complying with all the applicable provisions of this revenue procedure, the national office will notify the taxpayer that consent to make the change in method of accounting is not granted. In no event will an application under this revenue procedure be treated as an application under Rev. Proc. 97–27 (or any successor).

(3) Application changed . If the national office determines that a taxpayer has changed its method of accounting without complying with all the applicable provisions of this revenue procedure, the national office, in its discretion, may allow the taxpayer to (a) make appropriate adjustments to conform its change in method of accounting to the applicable provisions of this revenue procedure, and

September 8, 2008 618 2008–36 I.R.B.

Rev. Proc. 2008–43, 2008–30 I.R.B. 186, is modified to require a taxpayer to use a cut-off basis when changing to a rolling-average method of determining the current-year cost of LIFO inventory pursuant to section 22.02(1)(a)(v) of the APPENDIX of this revenue procedure.

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