TOs submit revisions to Attachment F to Section II of the Tariff to apply the IRS’s ADIT proration formula to their actual (true-up) revenue requirements.  The revisions are intended to maintain compliance with the IRS’s depreciation normalization requirements and to ensure their continued ability to use accelerated depreciation.  In an April 1, 2022 IRS Private Letter Ruling (“PLR”), the IRS held that the IRS’s depreciation normalization rules require the application of the ADIT proration formula in the actual (true-up) revenue requirement if the IRS’s proration formula was required to be applied in the calculation of the forecasted transmission revenue requirement.  The proposed Revisions are intended to be consistent with the PLR.