The change in early 2002 allowing taxpayers reporting Commodity Credit Corporation (CCC) loans1 as income to switch automatically to treating CCC loans as loans was a revolutionary change that has provided greater flexibility in terms of marketing decisions for program crops.2 That development has allowed farm taxpayers to shift freely from treating CCC loans as income to treating CCC loans as loans3 which, coupled with the statutory authority to allow taxpayers to elect to treat CCC loans as income,4 has allowed taxpayers to switch back and forth in their reporting of Commodity Credit Corporation loans.5 However, some have felt that the IRS requirement to send a copy of the Form 3115 directly to the Internal Revenue Service6 may have served as a subtle warning that the procedure was under some degree of scrutiny.