SECTION 2. BACKGROUND
Internal Revenue Bulletin 2012-14 · 2026-10-03 edition · updated 2026-10-04 · United States
.01 The Internal Revenue Service (IRS) and the Treasury Department recently issued temporary regulations under §§ 1.162–3T, 1.162–4T, 1.263(a)–1T, 1.263(a)–2T, and 1.263(a)–3T (T.D. 9564, 2012–14 I.R.B. 614 [76 Fed. Reg. 81,060]). Section 1.162–3T provides rules for materials and supplies. Section 1.162–4T provides rules for amounts paid or incurred for repairs and maintenance. Section 1.263(a)–1T provides general rules for capital expenditures. Section 1.263(a)–2T provides rules for amounts paid or incurred for the acquisition and production of tangible property. Section 1.263(a)–3T provides rules for amounts paid or incurred for the improvement of tangible property. The sections generally are effective for taxable years beginning on or after January 1, 2012.
.02 Except as otherwise expressly provided by the Internal Revenue Code or the regulations thereunder, § 446(e) and § 1.446–1(e)(2) require a taxpayer to secure the consent of the Commissioner before changing a method of accounting for federal income tax purposes.
.03 Sections 1.162–3T(i), 1.162–4T(b), 1.263(a)–1T(f), 1.263(a)–2T(j), and 1.263(a)–3T(o) provide that a taxpayer seeking to change to a method of accounting provided in the temporary regulations must secure the consent of the Commis
sioner in accordance with the requirements of § 1.446–1(e).
.04 Section 1.446–1(e)(3)(ii) authorizes the Commissioner to prescribe administrative procedures setting forth the terms and conditions necessary for a taxpayer to obtain consent to change a method of accounting. Rev. Proc. 2011–14 provides procedures by which a taxpayer may obtain automatic consent from the Commissioner to change to a method of accounting described in the APPENDIX of Rev. Proc. 2011–14. .05 Section 4.01 of this revenue procedure modifies the APPENDIX of Rev. Proc. 2011–14 by reserving sections 3.05 and 3.06 because they are obsolete for taxable years beginning on or after January 1, 2012. Section 4.02 of this revenue procedure modifies the APPENDIX of Rev. Proc. 2011–14 by adding sections 3.10 through 3.19 and sections 10.08 to 10.10 to the APPENDIX to provide additional changes in methods of accounting that are consistent with § 1.162–3T, § 1.162–4T, § 1.263(a)–1T, § 1.263(a)–2T, or § 1.263(a)–3T. In addition, sections 6.20 and 10.07 of the Appendix of Rev. Proc. 2011–14 are modified to provide changes in methods of accounting that are consistent with § 1.162–3T and § 1.263(a)–2T.
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