SECTION 2. BACKGROUND

The use of statistical sampling is provided in several items of published guidance. See, for example, Rev. Proc. 2011–35, 2011–25 I.R.B. 890 (provides safe harbor methodologies to determine basis in stock acquired in transfer basis transactions); Rev. Proc. 2004–29, 2004–1 C.B. 918 (provides the statistical sampling methodology that a taxpayer may use in establishing the amount of substantiated meal and entertainment expenses that are excepted from the 50% deduction disallowance under section 274(n)(1)); Rev. Proc. 2007–35, 2007–1 C.B. 1349 (addresses when statistical sampling may be used for purposes of section 199 (income attributable to domestic production activities)); and Rev. Proc. 72–36, 1972–2 C.B. 771 (sets forth statistical sampling guidelines for determining the redemption rate of trading stamps). If statistical sampling is determined to be appropriate under prior published guidance or under this revenue procedure, a taxpayer may use only the statistical sampling procedures set forth in this revenue procedure. Thus, any published guidance in effect prior to the effective date of this revenue procedure that permits statistical sampling is modified and amplified by this revenue procedure.