- 26 - Tax Reform Act of 1986, Pub. L. 99-514, sec. 801(d), 100 Stat. 2348. Section 448(d)(7) provides coordination with section 481 for those taxpayers that are required by section 448(a) to change from the cash method of accounting. Section 481 was enacted during 1954. It was designed to prevent items of income or expense from being omitted or duplicated as a result of a change in method of accounting initiated by either the taxpayer or the Government. S. Rept. 1622, 83d Cong., 2d Sess. 307-311 (1954). Prior to the enactment of section 481, consistent with rules laid down by the decided cases, adjustments needed to prevent such omission or duplication could be made only if the change in method of accounting was initiated by the taxpayer. Dearborn Gage Co. v. Commissioner, 48 T.C. 190, 200 (1967); S. Rept. 1622, supra at 307-311. The provision does not apply, however, to adjustments attributable to years before 1954 unless the change in method of accounting is initiated by the taxpayer. Sec. 481(a)(2). Section 481(c) provides that a spread of the section 481(a) adjustment over more than 1 year is allowed only as permitted under regulations. Regulations interpreting section 481(c) provide that a section 481(a) adjustment may be taken into account under terms and conditions agreed to by the Commissioner and the taxpayer. Sec. 1.481-5, Income Tax Regs. Absent a provision similar to the cessation-of-business acceleration provision, any portion of a section 481(a)Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011