SECTION 23. LAST-IN — Internal Revenue Bulletin 2025-24

(LIFO) INVENTORIES (§ 472).

01 Change from the LIFO inventory method

(1) Description of change (a) In general . This change applies to a taxpayer that wants to:

(i) change from the LIFO inventory method for all its LIFO inventory or for the entire content of one or more dollar-value pools; and

(ii) change to a permitted method or methods as determined in section 23. 01(1) (b) of this revenue procedure.

(b) Method to be used (i) Determining the permitted method to be used . A taxpayer may change to one or more non-LIFO inventory methods for the LIFO inventories that are the subject of this accounting method change, but only if the selected non-LIFO method is a permitted method for the inventory goods to which it will be applied. For example, a heavy equipment dealer may change to the specific identification method for new heavy equipment inventories and the replacement cost method, as described in Rev. Proc. 2006-14, 2006-1 C. B. 350, for heavy equipment parts inventories.

(ii) Permitted method defined . For purposes of this section 23. 01, an inventory method (identification or valuation, or both) is a permitted method if it is specifically permitted for the inventory goods by the Code, the regulations, or other guidance published in the Internal Revenue

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Bulletin, or a decision of the United States Supreme Court and if the taxpayer is neither prohibited from using that method nor required to use a different inventory method for those inventory goods. A permitted method includes a method described in § 1. 471-1(b)(4), (5) or (6), as applicable, provided the taxpayer is a small business taxpayer as defined in section 22. 18(2) of this revenue procedure.

(iii) Determining permitted method . Whether an inventory method is a permitted method is determined without regard to the types and amounts of costs capitalized under the taxpayer’s method of computing inventory cost. See § 263A and the regulations thereunder, which govern the types and amounts of costs required to be included in inventory cost for taxpayers subject to those provisions.

(2) Eligibility rules inapplicable . (a) The eligibility rule in section 5. 01(1) (f) of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, does not apply for the first taxable year that the taxpayer does not or will not comply with the requirements of § 472(e) (2) because the taxpayer has applied or will apply International Financial Reporting Standards in its financial statements or because the taxpayer has been acquired by an entity that has not or will not use the LIFO method in its financial statements.

(b) For a change by a small business taxpayer to a permitted method described in the last sentence of section 23. 01(1) (b)(ii) of this revenue procedure, if the taxpayer changed from accounting for inventory in accordance with § 471(c), proposed § 1. 471-1(b) or § 1. 471-1(b), as applicable, to accounting for inventory in accordance with § 472 and the accompanying regulations within the prior five taxable years ending with the year of change, and such change was made in the first taxable year that the taxpayer did not qualify as a small business taxpayer, then such change is disregarded for purposes of section 5. 01(1)(f) of Rev. Proc. 2015-13.

(3) Limitation on LIFO election . The taxpayer may not re-elect the LIFO inventory method for a period of at least five taxable years beginning with the year of change unless, based on a showing of unusual and compelling circumstances, consent is specifically granted by the Commissioner to change the method of accounting at an earlier time. A taxpayer

that wants to re-elect the LIFO inventory method within a period of five taxable years (beginning with the year of change) must file a Form 3115 in accordance with the non-automatic change procedures in Rev. Proc. 2015-13. A taxpayer that wants to re-elect the LIFO inventory method after a period of five taxable years (beginning with the year of change) does not file a Form 3115 using the non-automatic change procedures in Rev. Proc. 2015-13, but, rather, must file a Form 970, Appli- cation To Use LIFO Inventory Method, in accordance with § 1. 472-3.

(4) Effect of subchapter S election by corporation . See section 7. 03(4)(b) and (c) of Rev. Proc. 2015-13.

(5) Additional requirements . The taxpayer must complete the following statements and attach them to its Form 3115. If the taxpayer will use different methods for different inventory goods to which the change applies, the taxpayer must complete the statements for each of those different types of inventory goods.

(a) “The proposed method of identifying [ Insert description of inventory goods ] is the [ Insert method, as appropriate; that is, specific identification; FIFO; retail; etc. ] method. ”

(b) “The proposed method of valuing

[ Insert description of inventory goods ] is

[ Insert method, as appropriate; that is, cost; LCM; etc. ]. ”

(6) Pool split and partial termination . If a taxpayer must remove goods from a LIFO inventory pool because those goods are not within the scope of that pool ( for example, removing resale goods from a manufacturing pool), and if the taxpayer wants to change from the LIFO inventory method for those removed goods, the taxpayer may split the pool pursuant to section 23. 10 of this revenue procedure and then may change from the LIFO method pursuant to this section 23. 01. See section 23. 10(2) of this revenue procedure. The taxpayer must file a separate Form 3115 for each such change.

(7) Section 481(a) adjustment required . (a) General rule . A taxpayer changing from a LIFO inventory method must compute a § 481(a) adjustment for the year of change. See section 7. 02 of Rev. Proc. 2015-13. (b) Special rule for changes that would otherwise be implemented on a cut-off

basis . If a taxpayer is changing from the LIFO inventory method to a method of accounting that is implemented on a cutoff basis under another section of this revenue procedure ( see, e.g., sections 22. 06, 22. 07, and 22. 13 of this revenue procedure), the taxpayer’s § 481(a) adjustment is “the LIFO recapture amount” as defined in § 312(n)(4)(B) and (C). A taxpayer computing the § 481(a) adjustment under this special rule must then compute its ending inventory value for the year of change using the proposed method (that is, treat the deemed change from the first-in, first-out (FIFO) method to the proposed method on a cut-off basis).

(8) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 01 is “56. ” (9) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 02 Determining current-year cost under the LIFO inventory method

(1) Description of change . (a) Applicability . This change applies to a taxpayer using the LIFO inventory method that wants to change its method of determining current-year cost to:

(i) the actual cost of the goods most recently purchased or produced (most-recent-acquisitions method);

(ii) the actual cost of the goods purchased or produced during the taxable year in the order of acquisition (earliest-acquisitions method);

(iii) the average unit cost equal to the aggregate actual cost of all the goods purchased or produced throughout the taxable year divided by the total number of units so purchased or produced. See § 1. 4728(e)(2)(ii); (iv) the specific identification method; or

(v) a rolling-average method if the taxpayer uses that rolling-average method in accordance with Rev. Proc. 2008-43, 2008-30 I.R.B. 186, as modified by Rev. Proc. 2008-52, 2008-36 I. R. B. 587 ( see section 13).

(b) Inapplicability . This change does not apply to a taxpayer using the lower of cost or market method to determine current-year cost. A taxpayer using the lower

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of cost or market method that valued inventory below cost may not change to a proper cost valuation under this section 23. 02. (2) Manner of making change . This change is made using a cut-off basis and applies only to the computations of current-year cost after the beginning of the year of change. Accordingly, a § 481(a) adjustment is neither permitted nor required.

(3) Concurrent change to a rolling-av- erage method . A taxpayer making both a change to a rolling-average method of determining current-year cost for its LIFO inventory under this section 23. 02 and a change to a rolling-average method of accounting for non-LIFO inventories under Rev. Proc. 2008-43 ( see section 22. 13 of this revenue procedure) should file a single Form 3115 for both changes, in which case the taxpayer must enter the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, for information on making concurrent changes.

(4) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 02 is “57. ” (5) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 03 Alternative LIFO inventory method for retail automobile dealers

(1) Description of change (a) Applicability . This change applies to a taxpayer engaged in the trade or business of retail sales of new automobiles or new light-duty trucks (“automobile dealer”) that wants to change to the “Alternative LIFO method” described in section 4 of Rev. Proc. 97-36, 1997-2 C. B. 450, as modified by Rev. Proc. 2008-23, 2008-1 C. B. 664, for its LIFO inventories of new automobiles and new light-duty trucks. Light-duty trucks are trucks with a gross vehicle weight of 14,000 pounds or less, which also are referred to as class 1, 2, or 3 trucks. (b) Inapplicability . This change does not apply to an automobile dealer that uses the inventory price index computa

tion (IPIC) method for goods other than new automobiles, new light-duty trucks, parts and accessories, used automobiles, and used trucks.

(2) Manner of making change (a) Cut-off basis . This change is made using a cut-off basis and applies only to the computation of ending inventories after the beginning of the year of change. See section 5. 03(6) of Rev. Proc. 97-36 for more information regarding a cut-off basis. Accordingly, a § 481(a) adjustment is neither permitted nor required.

(b) Concurrent change from IPIC method . An automobile dealer using the IPIC method that also has parts and accessories, used automobiles, or used light-duty trucks (other goods) inventory may incorporate a change, using a cutoff basis, from IPIC to another acceptable LIFO method for those other goods into this change. When changing from IPIC to a dollar-value LIFO method for its other goods, the automobile dealer must establish separate inventory pools for new automobiles and new light-duty trucks, unless the automobile dealer also concurrently changes to the Vehicle-Pool Method ( see section 23. 08 of this revenue procedure). Further, the automobile dealer must establish a separate inventory pool for the parts and accessories. See section 6. 03(1)(b) of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, for information on making concurrent changes.

(i) the conditions in section 5. 03 of Rev. Proc. 97-36; and

(ii) for an automobile dealer changing from the IPIC method under this section 23. 03, the automobile dealer also must attach to its Form 3115 a schedule setting forth the classes of goods for which the automobile dealer has elected to use the LIFO method and the accounting method changes being made under this section 23. 03 for each class of goods. (3) Concurrent change to the Vehi- cle-Pool Method . A taxpayer making both a change to the Alternative LIFO Method under this section 23. 03 and a change to the Vehicle-Pool Method under Rev. Proc. 2008-23 ( see section 23. 08 of this revenue procedure) should file a single Form 3115 for both changes, in which case the

taxpayer must enter the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(4) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 03 is “58. ” (5) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 04 Used vehicle alternative LIFO method

(1) Description of change . This change applies to a taxpayer that sells used automobiles and used light-duty trucks (“used vehicle dealers”) that wants to change to the “Used Vehicle Alternative LIFO Method” as described in Rev. Proc. 2001-23, 2001-1 C.B. 784, as modified by Announcement 2004-16, 2004-1 C. B. 668, and Rev. Proc. 2008-23, 2008-1 C. B. 664. (2) Additional requirements . A taxpayer making this change must comply with the additional conditions set forth in section 5. 04 of Rev. Proc. 2001-23.

(3) Manner of making change (a) Cut-off basis . This change is made on a cut-off basis, which requires that the value of the taxpayer’s used automobile and used light-duty truck inventory at the beginning of the year of change must be the same as the value of that inventory at the end of the preceding taxable year, plus cost restorations, if any, required by section 5. 04(5) of Rev. Proc. 2001-23. Accordingly, a § 481(a) adjustment is neither permitted nor required.

(b) Bargain purchase . If the taxpayer has previously improperly accounted for a bulk bargain purchase, the taxpayer must, as part of this change, first change its method of accounting to comply with Hamilton Industries, Inc. v. Commis- sioner, 97 T. C. 120 (1991), and compute a § 481(a) adjustment for that part of the change. See Announcement 91-173, 1991-47 I. R. B. 29. Upon examination, if a taxpayer has properly changed under this section 23. 04 except for complying with this section 23. 04(3)(b), an examining agent may not deny the taxpayer the

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change. However, the taxpayer does not receive audit protection under section 8. 01 of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, with respect to the improper method of accounting for the bargain purchase. See section 8. 02(2) of Rev. Proc. 2015-13. Accordingly, the examining agent may make any necessary adjustments in any year for which the period of limitations on assessment and collection of tax is open to effect compliance with Hamilton Indus- tries, Inc.

(c) New base year . In effecting a change to the Used Vehicle Alternative LIFO Method under this revenue procedure, the taxpayer must retain any LIFO inventory cost increments previously determined and the value of those increments. Instead of using the earliest taxable year for which the taxpayer adopted LIFO as the base year, the taxpayer must use the year of change as the new base year in determining the value of all existing LIFO cost increments for the year of change and later taxable years. (The cumulative index at the beginning of the year of change is

00). The taxpayer must restate the baseyear cost of all LIFO cost increments at the beginning of the year of change in terms of new base-year costs, using the year of change as the new base year, and must recompute the indexes for previously determined inventory increments accordingly. The new base-year cost of a pool is equal to the total current-year cost of all the vehicles in the pool.

(d) Form 3115 . A completed Form 3115 includes the completion of Part I of Schedule C.

(4) Concurrent change from IPIC method . A used vehicle dealer using the IPIC method that also has parts and accessories, new automobiles, or new light-duty trucks (other goods) inventory may incorporate a change, using a cut-off basis, from IPIC to another acceptable LIFO method for those other goods into this change. When changing from IPIC to a dollar-value LIFO method for its other goods, the used vehicle dealer must establish separate inventory pools for new automobiles and new light-duty trucks, unless the used vehicle dealer also concurrently changes to the Vehicle-Pool Method ( see section 23. 08 of this revenue procedure). Further, the used vehicle dealer must establish a separate inventory pool for the

parts and accessories. See section 6. 03(1) (b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(5) Concurrent change to the Vehi- cle-Pool Method . A taxpayer making both a change to the Used Vehicle Alternative LIFO Method under this section 23. 04 and a change to the Vehicle-Pool Method under Rev. Proc. 2008-23 ( see section 23. 08 of this revenue procedure) should file a single Form 3115 for both changes, in which case the taxpayer must enter the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(6) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 04 is “59. ” (7) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 05 Determining the cost of used vehi- cles purchased or taken as a trade-in

(1) Description of change (a) Applicability . This change applies to a taxpayer using the LIFO inventory method that wants to:

(i) determine the cost of used vehicles acquired by trade-in using the average wholesale price listed by an official used vehicle guide on the date of the trade-in. See Rev. Rul. 67-107, 1967-1 C. B. 115. The taxpayer must consistently use the official used vehicle guide selected unless the taxpayer receives permission to use a different guide;

(ii) use a different official used vehicle guide for determining the cost of used vehicles acquired by trade-in;

(iii) determine the cost of used vehicles purchased for cash using the actual purchase price of the vehicle; or

(iv) reconstruct the beginning-of-theyear cost of used vehicles purchased for cash using values computed by national auto auction companies based on vehicles purchased for cash. The national auto auction company selected must be consistently used.

(b) Inapplicability . This change does not apply to a taxpayer that adopted or

changed to the Used Vehicle Alternative LIFO Method ( see section 23. 04 of this revenue procedure).

(2) Manner of making change . This change is made on a cut-off basis and applies only to used vehicles acquired on or after the beginning of the year of change. Accordingly, a § 481(a) adjustment is neither permitted nor required.

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 05 is “60. ” (4) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 06 Change to the inventory price index computation (IPIC) method

(1) Description of change . This change applies to a taxpayer that wants to change:

(a) from a non-IPIC LIFO inventory method to the IPIC method in accordance with all relevant provisions of § 1. 4728(e)(3); or (b) from the IPIC method as described in T. D. 7814, 1982-1 C. B. 84, (March 15, 1982) (the old IPIC method) to the IPIC method as described in § 1. 472-8(e)(3) ( see T. D. 8976, 2002-1 C. B. 421, (January 8, 2002)) (the new IPIC method), which includes the following required changes (if applicable):

(i) from using 80% of the inventory price index (IPI) to using 100% of the IPI to determine the base-year cost and dollar-value of a LIFO pool(s);

(ii) from using a weighted arithmetic mean to using a weighted harmonic mean to compute an IPI for a dollar-value pool(s); and

(iii) from using a components-of-cost method to define inventory items to using a total-product-cost method to define inventory items.

(3) Bargain purchase . If the taxpayer has previously improperly accounted for a bulk bargain purchase, the taxpayer must, as part of this change, first change its method of accounting to comply with

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average, detailed expenditure categories of the monthly CPI Detailed Report or Table 9 (PPI and percent changes for commodity and service groupings and individual items, not seasonally adjusted) of the monthly PPI Detailed Report (formerly, Table 6). See § 1. 472-8(e)(3)(iii)(C) for principles concerning the assignment of inventory items to BLS categories under the IPIC method. As part of this change, a taxpayer may separate a reassigned item from an inappropriate pool and combine the reassigned item with items in an appropriate pool. See § 1. 472-8(g)(2) for principles concerning the manner of combining and separating dollar-value pools;

(g) change the representative month when necessitated because of a change in taxable year or a change in method of determining current-year cost made pursuant to section 23. 02 of this revenue procedure. See § 1. 472-8(e)(3)(iii)(B) for principles concerning the determination of a representative month under the IPIC method. A change in method of determining current-year cost and a change of the representative month may be made using a single Form 3115, provided the taxpayer enters the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115;

(h) change from using preliminary BLS price indexes to using final BLS price indexes to compute an inventory price index, or vice versa . See § 1. 472-8(e)(3) (iii)(D)( 2 ) for principles concerning the selection of BLS price indexes under the IPIC method; and

(i) change from using a representative appropriate month to using an appropriate month. See § 1. 472-8(e)(3)(iii)(B)( 3 ) for principles concerning the selection of an appropriate month.

(2) Certain eligibility rule inapplicable . The eligibility rule in section 5. 01(1)(f) of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, does not apply to the changes described in sections 23. 07(1)(d), (f) in the case of a taxpayer using the 10 percent method described in § 1. 472-8(e)(3)(iii)(C)( 2 ), and (g) of this revenue procedure.

(3) Manner of making change . (a) Cut-off basis . These changes are made on a cut-off basis and apply only to the computation of ending inventories after the beginning of the year of change.

Hamilton Industries, Inc. v. Commis- sioner, 97 T. C. 120 (1991), and compute a § 481(a) adjustment for that part of the change. See Announcement 91-173, 1991-47 I. R. B. 29. Upon examination, if a taxpayer has properly changed under this section 23. 06 except for complying with section 23. 06(3) of this revenue procedure, an examining agent may not deny the taxpayer the change. However, the taxpayer does not receive audit protection under section 8. 01 of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, with respect to the improper method of accounting for the bargain purchase. See section 8. 02(2) of Rev. Proc. 2015-13. Accordingly, the examining agent may make any necessary adjustments in any year for which the period of limitations on assessment and collection of tax is open to effect compliance with Hamil- ton Industries, Inc.

(4) Concurrent automatic changes (a) A taxpayer making this change and to change its method of determining current-year cost under section 23. 02 of this revenue procedure for the same year of change may file a single Form 3115 for both changes, provided the taxpayer enters the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(b) A taxpayer making this change and to change its method of pooling to IPICmethod pools described in § 1. 472-8(b) (4) or § 1. 472-8(c)(2) under section 23. 07 of this revenue procedure for the same year of change may file a single Form 3115, provided the taxpayer enters the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(c) A taxpayer making this change and a change to its method of pooling under section 23. 10 of this revenue procedure for the same year of change may file a single Form 3115, provided the taxpayer enters the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev.

Proc. 2015-13 for information on making concurrent changes.

(5) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 06 is “61. ” (6) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 07 Changes within the inventory price index computation (IPIC) method

(1) Description of change . This change applies to a taxpayer using the IPIC method described in § 1. 472-8(e)(3) as revised by T. D. 8976, 2002-1 C. B. 421, (new IPIC method) that wants to make one or more of the following changes:

(a) change from the double-extension IPIC method to the link-chain IPIC method, or vice versa . See § 1. 472-8(e) (3)(iii)(E) for principles concerning the computation of the inventory price index under the double-extension IPIC method and the link-chain IPIC method;

(b) change to or from the 10 percent method. See § 1. 472-8(e)(3)(iii)(C) for principles concerning the assignment of inventory items to Bureau of Labor Statistics (BLS) categories under the IPIC method;

(c) change to IPIC-method pools described in § 1. 472-8(b)(4) or § 1. 4728(c)(2), including a change to begin or discontinue applying one or both of the 5 percent pooling rules;

(d) change to combine or separate pools as a result of the application of a 5 percent pooling rule described in § 1. 4728(b)(4) or § 1. 472-8(c)(2); (e) change its selection of BLS table from Table 3 (Consumer Price Index for All Urban Consumers (CPI-U): U. S. city average, detailed expenditure categories) of the monthly CPI Detailed Report to Table 9 (Producer price indexes (PPI) and percent changes for commodity and service groupings and individual items, not seasonally adjusted) of the monthly PPI Detailed Report (formerly, Table 6), or vice versa . See § 1. 472-8(e)(3)(iii)(B)(2) for principles concerning the selection of a BLS table under the IPIC method;

(f) change the assignment of one or more inventory items to BLS categories under either Table 3 (CPI-U): U. S. City

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Accordingly, a § 481(a) adjustment is neither permitted nor required.

(b) New base year . A taxpayer that changes pursuant to sections 23. 07(1)(a), (b), and (e) of this revenue procedure must establish a new base year in the year of change.

(4) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 07 is “62. ” (5) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 08 Changes to the Vehicle-Pool Method

(1) Description of change . This change applies to a retail dealer or wholesale distributor (“reseller”) of cars and light-duty trucks that wants to change to the “Vehicle-Pool Method” as described in Rev. Proc. 2008-23, 2008-1 C. B. 664.

(2) Manner of making change . (a) Cut-off basis . This change is made on a cut-off basis and applies only to the computation of ending inventories after the beginning of the year of change. Accordingly, a § 481(a) adjustment is neither permitted nor required. A reseller that changes its method of pooling under Rev. Proc. 2008-23 and this section 23. 08 must comply with § 1. 472-8(g).

(b) New base year . Instead of using the earliest taxable year for which the reseller adopted the LIFO method for any items in a pool, the reseller must use the year of change as the base year when determining the LIFO value of that pool for the year of change and subsequent taxable years (that is, the cumulative index at the beginning of the year of change is 1. 00). The reseller must restate the base-year cost of all layers of increment in a pool at the beginning of the year of change in terms of new baseyear cost. For an example of establishing a new base year, see § 1. 472-8(e)(3)(iv) (B)( 1 )( ii ).

(3) Concurrent change to the Alter- native LIFO Method or the Used Vehi- cle Alternative LIFO Method . A reseller making both a change to the Vehicle-Pool Method under this section 23. 08 and a change to the Alternative LIFO Method under Rev. Proc. 97-36 ( see section 23. 03 of this revenue procedure) or the Used

Vehicle Alternative LIFO Method under Rev. Proc. 2001-23 ( see section 23. 04 of this revenue procedure) should file a single Form 3115 for both changes, in which case the taxpayer must enter the designated automatic accounting method change numbers for both changes on the appropriate line on that Form 3115. See section 6. 03(1)(b) of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, for information on making concurrent changes.

(4) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 08 is “112. ” (5) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number). . 09 Changes within the used vehicle alternative LIFO method

(1) Description of change . This change applies to a taxpayer using the “Used Vehicle Alternative LIFO Method” as described in Rev. Proc. 2001-23, 2001-1 C.B. 784, as modified by Announcement 2004-16, 2004-1 C. B. 668, and Rev. Proc. 2008-23, 2008-1 C. B. 664, that wants to change the particular “official used vehicle guide” utilized by the taxpayer in connection with the Used Vehicle Alternative LIFO Method or any change in the precise manner of its utilization (for example, a change in the specific guide category that a taxpayer uses to represent vehicles of average condition for purposes of section 4. 02(5)(a) of Rev. Proc. 2001-23).

(b) New base year . A taxpayer that changes its method pursuant to this section 23. 09 must establish a new base year in the year of change.

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 09 is “140. ” (4) Contact information . For further information regarding a change under

this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).. 10 Changes to dollar-value pools of manufacturers

(1) Description of change . This change applies to a manufacturer that:

(a) purchases goods for resale (resale goods) and, thus, must reassign resale goods from the pool(s) it maintains for the goods it manufactures to one or more resale pools;

(b) wants to change from using multiple pools described in § 1. 472-8(b)(3) to using natural business unit (NBU) pools described in § 1. 472-8(b)(1), or vice versa ; or

(c) wants to reassign items in NBU pools described in § 1. 472-8(b)(1) into the same number or a greater number of NBU pools.

(2) Manner of making change . This change is made on a cut-off basis and applies only to the computation of ending inventories after the beginning of the year of change. Accordingly, a § 481(a) adjustment is neither permitted nor required. A taxpayer that changes its method of pooling pursuant to this section 23. 10 must combine or separate pools as required by § 1. 472-8(g). If a taxpayer splits a pool into two or more permissible pools pursuant to this section 23. 10, which must be implemented on a cut-off basis, the taxpayer then may file a separate Form 3115 to change from the LIFO inventory method for one or more of the resulting pools pursuant to section 23. 01 of this revenue procedure, which must be implemented with a § 481(a) adjustment.

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 23. 10 is “141. ” (4) Contact information . For further information regarding a change under this section, contact Mia Romano at (202) 317-7007 (not a toll-free number).