The IRS Industry Director, Heavy Manufacturing and Transportation, Large and Mid Size Business Division has issued a September 15, 2009, memorandum entitled Tier III - Field Directive on the Planning and Examination of IRC § 263A issues in the Auto Dealership Industry (download below).
The memo, which is not an official pronouncement of law or the position of the IRS, provides direction to IRS field examiners on how to conduct UNICAP audits of franchised car and truck dealers and includes an “audit tool kit.” It states, in part: “In order to encourage compliance and to allow taxpayers in the auto dealership industry an opportunity to voluntarily change their methods of accounting to comply with the legal reasoning outlined in TAM 200736026 (209KB 
.pdf), the IRS has determined that it will suspend examination of auto dealership § 263A issues effective September 15, 2009 and continuing through December 31, 2010.”
Another portion of the memo addresses § 263A examinations already in progress. Dealers should consult with their tax practitioner concerning this development.
Please download all four documents below:
Tier III - Field Directive on the Planning and Examination of IRC § 263A issues in the Auto Dealership Industry (307KB .pdf),
Audit Plan — Auto Dealer § 263A Resale Audit Plan (49KB .pdf)
Terms and Definitions — IRC § 263A Audit Plan Key Terms and Definitions, Steps 1-12 (80KB .pdf)
Computational Spreadsheet — Retail Workpaper Template (73KB 
.xls)