97-27, on the other hand, deprives taxpayers of an unqualified right to a change in method under either the 90-day or 120-day windows where an accounting method
"issue" is "under consideration" by Exam.
Thus, in general, once the accounting method
is adopted, the controlling domestic shareholders must follow the method change procedures set forth in either Rev.
91-31 because it would in effect mean that the IRS can deny (through its control over procedures governing accounting method
changes) taxpayers the right to conform to a tax treatment (exclusion from income) explicitly sanctioned by the Supreme Court.
Among these reasons is the possibility that a taxpayer will come under IRS examination before it has the opportunity to file its accounting method
11) Further, a change in a taxpayer's method of accounting generally results in an adjustment to prevent amounts from being duplicated or omitted in determining taxable income when the taxpayer uses a different accounting method
from the method used in the preceding year.
In most cases, the principal method is the accounting method
used by the acquiring corporation before the Sec.
5) Where there is uncertainty about whether a particular accounting method
is a Category A or B method, taxpayers will generally refrain from seeking a voluntary change rather than risk a retroactive adjustment.
S consent, even if the taxpayer has an advance consent accounting method
change request pending with the IRS National Office (Sec.
Having reported the transactions as leases on its original returns, the court said, the taxpayer could not change that accounting method
without the Commissioner's consent.
On September 11,2003, the taxpayer submitted a Form 3115, Application for Change in Accounting Method
, requesting permission to change its accounting method
for self-constructed property under Sec.
For property that is vested at the time of transfer, a special exception allows the employer to take a deduction under its normal accounting method
The preamble explains that the "proposed regulations are a method of accounting to the extent they determine the timing of items" and adds that "[a] group's ability to change its manner of applying the final intercompany transaction regulations will be subject to the generally applicable rules for accounting method