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Rev. Proc. 92-67, 1992-2 C.B. 429 (election under § 1278(b) to include market discount in

Internal Revenue Bulletin 2024-1 · 2026-10-03 edition · updated 2026-10-04 · United States

income currently or election under § 1276(b) to use constant interest rate to determine accrued market discount).

(4) See Appendix F for the list of revenue procedures for automatic changes in accounting period.

.23 In addition to this section 9, the following sections of this revenue procedure apply to automatic change requests and non-automatic change requests:

1 (purpose of this revenue procedure);

2.01 (definition of “letter ruling”);

2.02 (definition of “closing agreement”);

2.05 (oral guidance);

3.01 (issues under the jurisdiction of the Associate Chief Counsel (Corporate));

3.02 (issues under the jurisdiction of the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes));

3.03 (issues under the jurisdiction of the Associate Chief Counsel (Financial Institutions and Products));

3.04 (issues under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting));

3.05 (issues under the jurisdiction of the Associate Chief Counsel (International));

January 2, 2024 58 Bulletin No. 2024–1

3.06 (issues under the jurisdiction of the Associate Chief Counsel (Passthroughs and Special Industries));

5.03(2) (period of limitation when filing a request for extensions of time for making an election or for other relief under § 301.9100);

6.02 (letter rulings ordinarily not issued in certain areas because of the factual nature of the problem);

6.05 (letter rulings ordinarily not issued to business associations or groups);

6.06 (letter rulings ordinarily not issued where the request does not address the tax status, liability, or reporting obligations of the requester);

6.08 (letter rulings ordinarily not issued on Federal tax consequences of proposed legislation);

6.10 (letter rulings not issued on frivolous issues);

6.12 (letter rulings not issued on alternative plans or hypothetical situation);

7.01(1) (statement of facts and other information);

7.01(10) (statement of supporting authorities);

7.01(14) (authorized representatives);

7.01(15) (Power of Attorney and Declaration of Representative);

7.02(2) (power of attorney used to indicate recipient of a copy or copies of a letter ruling or a determination letter);

7.02(4) (expedited handling);

7.05(2) (notify Associate office if a return, amended return, or claim for refund is filed while request is pending and attach request to the return);

8.01 (receipt and control of the request, and referral to the appropriate Associate office);

8.02 (contact taxpayer within 21 calendar days);

8.04 (not bound by informal opinion expressed);

10 (scheduling conferences);

Bulletin No. 2024–1 59 January 2, 2024

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