SECTION 10. EFFECT OF CONSENT

.01 In general . A taxpayer ordinarily may rely on the grant of consent in SECTION 9 (in the case of an automatic change) or in a letter ruling issued to the taxpayer (in the case of a non-automatic change) subject to the provisions of SECTIONS 7, 8, 10, 11, and 12 and section 11 of Rev. Proc. 2015–1 (or successor).

.02 Required change or modification of method of accounting . A taxpayer that changes to a method of accounting under this revenue procedure may be required to change or modify that method of accounting for any of the following reasons:

(1) the enactment of legislation; (2) a decision of the United States Supreme Court;

(3) the issuance of temporary or final regulations;

(4) the issuance of a revenue ruling, revenue procedure, notice, or other guidance published in the IRB;

(5) the issuance of written notice to the taxpayer that the change in method of accounting was granted in error or is not in accord with the current views of the IRS; or

(6) a change in the material facts on which the consent was based.

.03 Revoked or modified if found to be in error . The national office may revoke or modify a letter ruling issued under the non-automatic change procedures or the grant of consent in SECTION 9 for an automatic change by letter to the taxpayer giving notice of revocation or modification, if the national office determines, as a result of the director’s review under SECTION 12 or otherwise, that the letter ruling or grant of consent was issued in error or is not in accord with the current views of the IRS.

Except in rare or unusual circumstances, if a taxpayer that changes its method of accounting under this revenue procedure is subsequently required under this SECTION 10.03 to change (in the case of a revocation) or modify that method of accounting, the required

change or modification will not be applied retroactively, provided that:

(1) the taxpayer complied with all the applicable provisions;

(2) the taxpayer neither misstated nor omitted any material facts;

(3) the material facts on which the consent was based have not changed;

(4) the applicable law has not changed; and

(5) the taxpayer to whom consent was granted acted in good faith in relying on the consent, and applying the change in method of accounting or modification retroactively would be to the taxpayer’s detriment.

.04 Change treated as initiated by the taxpayer . For purposes of § 481, a change in method of accounting made under this revenue procedure is a change in method of accounting initiated by the taxpayer.