SECTION 6. NOTIFICATION BY A

DEFAULT SUCCESSOR UNDER § 1.1502–77(c)(4)

.01 In general . If a terminating agent has a default successor (as defined in § 1.1502–77(b)(4)), such default successor is the agent. Such default successor must provide notification to the Commissioner pursuant to the requirements set forth in this section 6 to insure that the default successor will receive communications from the Commissioner to the group and to insure that the Commissioner will act on the default successor’s communications to the Commissioner on behalf of the group.

.02 When to file . The appropriate time for the default successor to file the notification is after the terminating agent ceases to exist.

.03 Contents . The notification by the default successor under § 1.1502–77(c)(4) must be in writing and contain the following information:

(1) The heading “REV. PROC. 2015– 26: NOTIFICATION BY DEFAULT SUCCESSOR UNDER § 1.1502– 77(c)(4)” must be typed or legibly printed at the top of the notification;

(2) Name, address, and employer identification number of the terminated agent;

(3) Name, address, and employer identification number of the default successor and the consolidated return year(s) for which it is the agent;

(4) The name and employer identification number of the common parent under which the return(s) for which the default successor is the agent was (were) filed, if different from the agent named in section 6.03(2) of this revenue procedure; (5) The Internal Revenue Service Center (Service Center) where the consolidated return(s) was (were) or will be filed, as the case may be, for the consolidated

return year(s) for which the default successor is the agent;

(6) The date of termination of the prior agent;

(7) The name, address, and phone number of the Examination Team Manager, Appeals Officer or Counsel Attorney, if any, who currently has jurisdiction of the consolidated return year(s) for which the default successor is the agent; and

(8) A statement in which the default successor, if it was not a member of the group during the consolidated return year(s) for which it is the default successor, acknowledges that it is primarily liable as a successor of the former agent of the group for the consolidated tax liability for such consolidated return year(s).

.04 Signature requirements . The notification by a default successor must contain the following declaration, signed by a person duly authorized to sign on behalf of the default successor: Under penalties of perjury, I declare that I am autho- rized to submit this notification on be- half of the default successor and that, to the best of my knowledge, the informa- tion provided is true, correct, and com- plete.

.05 No approval required . Commissioner approval is not required for a default successor, but the Commissioner is not required to send communications to, or act on communications from, a default successor until it provides notification under this section 6.