SECTION 28. INCOME FROM

SOURCES WITHIN THE UNITED STATES (§ 861)

.01 Transactions involving computer programs .

(1) Description of change . This change applies to a taxpayer that wants to change its method of accounting for transactions involving computer programs to conform to the provisions of § 1.861–18. This change applies only to transactions occurring pursuant to contracts entered into on or after December 31, 1998.

(2) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under section 28.01 of this APPENDIX is “69.” See section 6.02(4) of this revenue procedure.

2008–36 I.R.B. 673 September 8, 2008

(a) identify the categories of loans to which the new method will apply; and

(b) describe any “additional categories” permitted under section 4.03 of Rev. Proc. 97–39.

(6) No audit protection . A taxpayer does not receive audit protection under section 7 of this revenue procedure in connection with this change.

(7) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under section 31.01 of this APPENDIX is “72.” See section 6.02(4) of this revenue procedure.

(8) Contact information . For further information regarding a change under this section, contact William E. Blanchard at 202–622–3950 (not a toll-free call).

.02 Reserved .