SECTION 13. REQUEST TO REVISE

THE YEAR OF CHANGE FOR A NON-AUTOMATIC CHANGE

.01 In general . The taxpayer may request, and the national office ordinarily will allow, the taxpayer to revise the year of change for a Form 3115 for a nonautomatic change to a subsequent taxable year, but no later than the taxpayer’s current taxable year (with no additional user fee), in lieu of submitting a new Form 3115 for the subsequent taxable year, under the following conditions:

(1) Timely written request . (a) In general . The taxpayer must submit a written request pursuant to SECTION 13.03 to revise the year of change for a Form 3115 on or after, but not before, the first day of the fourth month following the month in which the taxpayer’s federal income tax return is due (excluding any extension) for the original year of change requested on the Form 3115. For example, a calendar year corporation that files a Form 3115 on December 16, 2014, for a 2014 year of change may submit a written request to revise the year of change to 2015 on or after, but not before, July 1, 2015.

(b) Form 3115 filed on or before the last day of the sixth month of the year of change . If the taxpayer filed its Form 3115 on or before the last day of the sixth month of the year of change, the taxpayer may submit a written request pursuant to SECTION 13.03 to revise the year of change on or after, but not before, the first day of the taxable year following the original year of change requested on the Form 3115. For example, a calendar year taxpayer that files a Form 3115 on June 28, 2014, for a 2014 year of change may submit a written request to revise the year of change to 2015 on or after, but not before, January 1, 2015. This SECTION 13.01(1)(b) does not apply to a taxpayer filing a Form 3115 for a year of change that is a short taxable year.

(2) Pending Form 3115 . The Form 3115 is pending in the national office (for example, the national office has not issued a letter ruling) on the date of the request.

(3) Acceleration and revision of § 481(a) adjustment . Unless the Commissioner has determined that the requested change in method of accounting will be made using a cut-off method or a modified cut-off method:

February 2, 2015 444 Bulletin No. 2015–5

The request must be either submitted to the applicable address in section 9.08(6) of Rev. Proc. 2015–1 (or successor) or faxed to a fax number provided by the national office contact person for the pending Form 3115. If faxed, a copy of the request and an original signed penalties of perjury statement must also be mailed or delivered to the applicable address in section 9.08(6) of Rev. Proc. 2015–1 (or successor).

.04 Notification of approval or denial . The national office will notify the taxpayer of the approval or denial of the taxpayer’s request to revise the year of change for a pending 3115.

.05 National office’s discretion to deny a request . The national office may deny a taxpayer’s request for a revised year of change for a pending Form 3115 if the national office determines it would not be in the interest of sound tax administration to allow the taxpayer to revise the year of change. A taxpayer is not entitled to a conference with the national office if the request to revise the year of change for a pending Form 3115 is denied.