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The Revenue Procedures that are mentioned relate to accounting
methods that are being changed for the same issue that is currently in Appeals. The Rev Procs normally provide protection from audit
for prior years on the issue being changed. However, if the item being changed is one of the items under Appeals consideration, then this audit protection does not apply.
When completing the Form 3115, Part II, Item 5a, you should check "Yes" and check the Appeals box, and then list the office, phone number and tax years
. For Item B, you have to indicate if you have provided the Appeals office with a copy of the Form 3115 or not. Finally, for Item 5c, since you said the Appeals issue is different, you would mark this box as "No".
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