SECTION 1. INTRODUCTION

.01 In general. This Appendix B provides an extrapolation methodology that an eligible taxpayer may use in connection with a change to apply the NGSH Method. The extrapolation methodology described in this Appendix B provides the exclusive extrapolation methodology that is permitted under the NGSH Method for determining the amount of a § 481(a) adjustment.

.02 Scope. This Appendix B does not apply to a change to apply the NGSH Method if the taxpayer does not have a minimum of three representative years within the testing period as described in section 2.02(1) of this Appendix B.