Internal Revenue Bulletin: 2003-32
August 11, 2003
This procedure provides guidance for taxpayers seeking equitable relief from income tax liability under section 66(c) or section 6015(f) of the Code. Rev. Proc. 2000-15 superseded.
Changes in accounting periods; automatic approval for individuals. Procedures are provided by which certain individuals may obtain automatic approval of the Commissioner to change their annual accounting period under section 442 of the Code to the calendar year. Rev. Proc. 66-50 modified, amplified, and superseded, and Rev. Proc. 81-40 modified and superseded.
Depreciation of cable television distribution systems. This procedure provides a safe harbor method under which the Service will treat a node and fiber optic cable used in a cable television distribution system providing one-way and two-way communication services as the unit of property for computing depreciation under sections 167 and 168 of the Code. Rev. Proc. 2002-9 modified and amplified.
REIT loans; real estate asset; interest. This procedure sets forth a safe harbor under which a loan made by a real estate investment trust (REIT) that is secured either by a partnership interest in a partnership or by the sole membership interest in a disregarded entity will be treated as a real estate asset for purposes of sections 856(c)(4)(A) and 856(c)(5)(B) of the Code and the interest on the loan will be treated as interest on an obligation secured by a mortgage on real property or on an interest in real property for purposes of section 856(c)(3).
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