Change in method of accounting.
(2) Change in method of accounting. Any change in a taxpayer's method of accounting necessary to comply with this section and 1.4602 through 1.4605 is a change in method of accounting to which the provisions of section 446 and the regulations thereunder apply. For the first taxable year that includes January 11, 2001, a taxpayer is granted the consent of the Commissioner to change its method of accounting to comply with the provisions of this section and 1.4602 through 1.4605 for long-term contracts entered into on or after January 11, 2001. A taxpayer that wants to change its method of accounting under this paragraph (h)(2) must follow the automatic consent procedures in Rev. Proc. 9949 (199952 I.R.B. 725) (see 601.601(d)(2) of this chapter), except that the scope limitations in section 4.02 of Rev. Proc. 9949 do not apply. Because a change under this paragraph (h)(2) is made on a cut-off basis, a section 481(a) adjustment is not permitted or required. Moreover, the taxpayer does not receive audit protection under section 7 of Rev. Proc. 9949 for a change in method of accounting under this paragraph (h)(2). A taxpayer that wants to change its exempt-contract method of accounting is not granted the consent of the Commissioner under this paragraph (h)(2) and must file a Form 3115, Application for Change in Accounting Method, to obtain consent. See Rev. Proc. 9727 (19971 C.B. 680) (see 601.601(d)(2) of this chapter).