Rev. Proc. 69-8

Section 1. Purpose

The purpose of this Revenue Procedure is to state the conditions under which the Internal Revenue Service will accept one properly executed Form 872, Consent Fixing Period of Limitation Upon Assessment of Income and Profits Taxes, covering a parent corporation and any or all of its subsidiary corporations.

Sec. 2. Background

It is often necessary to examine the separately filed income tax returns of a number of subsidiary corporations in connection with the examination of the income tax return of the parent corporation. In order to protect the interests of the Government against the expiration of the period of limitation on assessment in such cases, it is sometimes necessary to secure consents from the subsidiaries, as well as from the parent. See section 6501(c)(4) of the Internal Revenue Code of 1954. A consent extending the period of limitation on assessment is also advantageous to the taxpayer in that it extends the period within which a claim for credit or refund may be filed. See section 6511(c) of the Code.

Sec. 3. Procedure

.01 In order to eliminate unnecessary paperwork, District Directors of Internal Revenue or, in cases under the jurisdiction of the Appellate Division, the Assistant Regional Commissioners--Appellate will accept a single consent on Form 872, provided certain conditions are met, as follows:

1 The name of the parent corporation and the number of subsidiary corporations named on an attached rider shall be inserted in the space provided for the name of the taxpayer on the Form 872. The rider attached to the Form 872 will contain a supplemental agreement and will clearly identify the parent and the specific subsidiaries by showing the name, address, identification number, and the particular taxable year of each subsidiary with respect to which the Form 872 is applicable. See Exhibit "A" for the format of the rider.

2 Both the consent and the rider shall be executed on behalf of the parent corporation and all the subsidiaries named on the rider by a duly authorized officer of the parent corporation who (1) is also a duly authorized officer of each of the subsidiaries, or (2) has been specifically authorized to execute a consent by powers of attorney executed by each of the subsidiaries. The consent must specifically show that the person signing for the parent and subsidiaries is signing in the capacity of an authorized officer of the parent corporation and as an authorized officer or attorney-in-fact for each and all of the listed subsidiaries.

3 In the event two or more officers of the parent corporation are authorized to sign for the various subsidiaries, in accordance with 2 above, the rider attached to the consent should be arranged to show the names of the subsidiaries for which each officer or attorney-in-fact is signing.

.02 The District Director will attach a statement to the income tax return of each of the subsidiary corporations indicating that a consent, Form 872, executed on behalf of the subsidiary has been secured and associated with the return of the parent. The statement will also show the name, address, and identification number of the parent corporation, the office in which the income tax return of the parent corporation was filed and the period of the extension agreed to in the consent.

                            Exhibit "A"