Rev. Proc. 90–39, 1990–2 C.B. 365, as clarified by Rev. Proc. 90–39A, 1990–2 C.B. 367. 1552 Consent to elect or change method of allocating affiliated group's consolidated federal income tax liability 4980B Rev. Proc. 87–28, 1987–1 C.B. 770 (treating references to former § 162(k) as if they were references to § 4980B). 7701(a)(40) and 7871(d) Indian tribal governments and subdivision of Indian tribal governments Rev. Proc. 84–37, 1984–1 C.B. 513, as modified by Rev. Proc. 86–17, 1986–1 C.B. 550, and Rev. Proc. 2003–1 (this revenue procedure) (provides guidelines for obtaining letter rulings recognizing Indian tribal government or tribal government subdivision status; also provides for inclusion in list of recognized tribal governments in revised versions of Rev. Proc. 2002–15, or in list of recognized subdivisions of Indian tribal governments in revised versions of Rev. Proc. 84–36, 1984–1 C.B. 510, as modified and made permanent by Rev. Proc. 86–17). 301.7701-2(a) Rev. Proc. 2002–22, 2002–14 I.R.B. 733 (specifies the conditions under which the Service will consider a letter ruling request that an undivided fractional interest in rental real property (other than a mineral property as defined in § 614) is not an interest in a business entity). estate Accounting methods; Rev. Proc. 97–27, 1997–1 C.B. 680, as modified by Rev. Proc. 97–30, 1997–1 C.B. 702, as modified and amplified by Rev. Proc. 2002–19, 2002–13 I.R.B. 696, and as amplified and clarified by Rev. Proc. 2002–54, 2002–35 I.R.B. 432; and Rev. Proc. 2003–1 (this revenue procedure) for which sections 1, 2.01, 2.02, 2.06, 3.01, 3.02, 3.03, 3.05, 5.02, 5.12, 5.14, 7.01, 7.02, 7.03, 8.01(1), 8.01(2), 8.01(3), 8.01(4), 8.01(5), 8.01(6), 8.01(8), 8.01(9), 8.01(10), 8.01(13), 8.01(14), 8.01(15), 8.02(2), 8.02(4), 8.02(5), 8.02(7), 8.02(8), 8.03(1), 8.04, 8.05, 8.06, 8.07, 8.08, 9, 10.01, 10.04, 10.05, 10.07, 10.08, 10.10(2), 10.11, 11, 12.01, 12.02, 15, and Appendix A are applicable. Accounting periods; changes in period Rev. Proc. 2002–39, 2002–22 I.R.B. 1046, as clarified and modified by Notice 2002–72, 2002–46 I.R.B. 843; and Rev. Proc. 2003–1 (this revenue procedure) for which sections 1, 2.01, 2.02, 2.06, 3.03, 5.02, 5.12, 5.14, 7.01, 7.02, 7.03, 8.01(1), 8.01(2), 8.01(3), 8.01(4), 8.01(5), 8.01(6), 8.01(8), 8.01(9), 8.01(10), 8.01(13), 8.01(14), 8.01(15), 8.02(2), 8.02(4), 8.02(5), 8.02(7), 8.03(1), 8.04, 8.05, 8.06, 8.07, 8.08, 9, 10.01, 10.04, 10.05, 10.07, 10.08, 11, 12, 15, and Appendix A are applicable. Classification of liquidating trusts Rev. Proc. 82–58, 1982–2 C.B. 847, as modified and amplified by Rev. Proc. 94–45, 1994–2 C.B. 684, and as amplified by Rev. Proc. 91–15, 1991-1 C.B. 484 (checklist questionnaire), as modified and amplified by Rev. Proc. 94–45. Earnings and profits determinations Rev. Proc. 75–17, 1975–1 C.B. 677; and Rev. Proc. 2003–1 (this revenue procedure) for which sections 2.06, 3.03, 8, 10.04, 10.06, and 11.05 are applicable. Rev. Proc. 91-14, 1991-1 C.B. 482 (checklist questionnaire). Estate, gift, and generation-skipping transfer tax issues Sec. 9.01 Leveraged leasing Rev. Proc. 2001–28, 2001–1 C.B. 1156, and Rev. Proc. 2001–29, 2001-1 C.B. 1160. Rate orders; regulatory agency; normalization A letter ruling request that involves a question of whether a rate order that is proposed or issued by a regulatory agency will meet the normalization requirements of § 168(f)(2) (preTax Reform Act of 1986, § 168(e)(3)) and former $$ 46(f) and 167(1) ordinarily will not be considered unless the taxpayer states in the letter ruling request whether (1) the regulatory authority responsible for establishing or approving the taxpayer's rates has reviewed the request and believes that the request is adequate and complete; and (2) the taxpayer will permit the regulatory authority to participate in any national office conference concerning the request. If the taxpayer or the regulatory authority informs a consumer advocate of the request for a letter ruling and the advocate wishes to communicate with the Service regarding the request, any such communication should be sent to: Internal Revenue Service, Associate Chief Counsel (Procedure & Administration), Attention CC:PA:T, P. O. Box 7604, Ben Franklin Station, Washington, D.C. 20044 (or, if a private delivery service is used: Internal Revenue Service, Associate Chief Counsel (Procedure & Administration), Attention CC:PA:T, Room 6561, 1111 Constitution Avenue, N.W., Washington, D.C. 20224). These communications will be treated as third party contacts for purposes of $ 6110. Unfunded deferred compensation Rev. Proc. 71-19, 1971–1 C.B. 698, as amplified by Rev. Proc. 92–65, 1992–2 C.B. 428. See Rev. Proc. 92–64, 1992–2 C.B. 422, as modified by Notice 2000–56, 2000–2 C.B. 393, for the model trust for use in Rabbi Trust Arrangements. Safe harbor revenue procedures .02 For requests relating to the following Code sections and subject matters, see the following safe harbor revenue procedures. 103 and 141-150 Rev. Proc. 93–17, 1993–1 C.B. 507 (change of use of proceeds); Rev. Proc. 97–13, 1997–1 Rev. Proc. 89–21, 1989–1 C.B. 842, as amplified by Rev. Proc. 90–32, 1990–1 C.B. 546. 664(d)(1) Qualification of trusts as charitable remainder annuity trusts Rev. Proc. 89–20, 1989–1 C.B. 841, as amplified by Rev. Proc. 90–30, 1990–1 C.B. 534. 664(d)(2) Qualification of trusts as charitable remainder unitrusts Automatic change revenue procedures .03 For requests to change an accounting period or accounting method, see the following automatic change revenue procedures published and/or in effect as of December 31, 2002. A taxpayer complying timely with an automatic change revenue procedure will be deemed to have obtained the consent of the Commissioner to change the taxpayer's accounting period or accounting method, as applicable. 442 The automatic change revenue procedures for obtaining a change in annual accounting peAdoptions, retention, or changes in riod include: Rev. Proc. 2002–37, 2002–22 I.R.B. 1030, as clarified and modified by Notice accounting periods 2002–72, 2002–46 I.R.B. 843 (certain corporations); Rev. Proc. 2002–38, 2002–22 I.R.B. 1037, as clarified and modified by Notice 2002–72, 2002–46 I.R.B. 843 (certain partnerships, S corporations, electing S corporations, or personal service corporations); Rev. Proc. 68–41, 1968–2 C.B. 943, as modified by Rev. Proc. 81-40, 1981–2 C.B. 605 (trusts held by certain fiduciaries needing a workload spread); and Rev. Proc. 66–50, 1966-2 C.B. 1260, as modified by Rev. Proc. 81–40 (individual seeking a calendar year). 446 Changes in accounting methods The automatic change revenue procedures for obtaining a change in method of accounting include: Rev. Proc. 2002–9, 2002–3 I.R.B. 327 (accounting method changes described in the Appendix to Rev. Proc. 2002–9 involving $$ 56, 77, 162, 166, 167, 168, 171, 174, 197, 263, 263A, 267, 404, 446, 448, 451, 454, 455, 460, 461, 467, 471, 472, 475, 585, 861, 985, 1272, 1273, 1278, 1281, and former 168), as modified and amplified by Announcement 2002–17, 2002–8 I.R.B. 561, Rev. Proc. 2002–19, 2002–13 I.R.B. 696, Rev. Proc. 2002–54, 2002–35 I.R.B. 432, Rev. Proc. 2002–65, 2002–41 I.R.B. 700 (certain taxpayers seeking to change their method of accounting for railroad track structure expenditures to the track maintenance allowance method provided in Rev. Proc. 2002–65), Rev. Rul. 2002–9, 2002–10 I.R.B. 614 (certain taxpayers seeking to change their method of accounting for impact fees), Rev. Proc. 2002–17, 2002–13 I.R.B. 676 (certain taxpayers seeking to change to the “replacement cost method” for valuing vehicle parts inventories), Rev. Proc. 2002–27, 2002–17 I.R.B. 802 (certain taxpayers seeking to change their method of accounting for depreciation of original and replacement tires of certain vehicles), Rev. Proc. 2002–33, 2002–20 I.R.B. 963 (revised sections 2.01 and 2.02 of the Appendix to reflect the depreciation provisions in $$ 168(k) and 1400L), Rev. Proc. 2002– 36, 2002–21 I.R.B. 993 (certain taxpayers seeking to change their method of accounting for capital cost reduction payments), Rev. Proc. 2002–28, 2002–18 I.R.B. 815 (certain qualifying small business taxpayers seeking to change to the cash receipts and disbursements method of accounting and/or to a method of accounting for inventoriable items as nonincidental materials and supplies), Rev. Proc. 2002–46, 2002–28 I.R.B. 105 (certain insurance companies seeking to change their method of accounting for premium acquisition expenses); Rev. Rul. 2002–46, 2002–29 I.R.B. 117 and Rev. Rul. 2002–73, 2002–45 I.R.B. 805 (certain taxpayers seeking to change their method of accounting for employer contributions to $ 401(k) plans or matching contributions to qualified defined contribution plans); Rev. Proc. 98–58, 1998–2 C.B. 710 (certain taxpayers seeking to change to the installment method of accounting under $ 453 for alternative minimum tax purposes for certain deferred payment sales contracts relating to property used or produced in the trade or business of farming); Rev. Proc. 97–43, 1997–2 C.B. 494 (certain taxpayers required to change their method of accounting as a result of making elections out of certain exemptions from dealer status for purposes of § 475); Rev. Proc. 92–67, 1992–2 C.B. 429 (certain taxpayers with one or more market discount bonds seeking to make a $ 1278(b) election or a constant interest rate election); Rev. Proc. 92–29, 1992–1 C.B. 748 (certain taxpayers seeking to use an alternative method under $ 461(h) for including common improvement costs in basis); and Rev. Proc. 91–51, 1991–2 C.B. 779 (certain taxpayers under examination that sell mortgages and retain rights to service the mortgages). Sec. 9.02 |