SECTION 12. LOSSES, EXPENSES

AND INTEREST WITH RESPECT TO TRANSACTIONS BETWEEN RELATED TAXPAYERS (§ 267)

.01 Change to comply with § 267 .

(1) Description of change . This change applies to a taxpayer that wants to change its method or methods of accounting to comply with the requirements of § 267, which disallows or defers certain deductions attributable to transactions between related taxpayers. However, this change applies to a change for stated interest only to the extent the stated interest is qualified stated interest (as defined in § 1.1273–1(c)).

(2) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under section 12.01 of this APPENDIX is “26.” See section 6.02(4) of this revenue procedure.

(3) Contact information . For further information regarding a change under this section, contact Steve Gee at 202–622–4970 (not a toll-free call).

.02 Reserved .