- 31 -
736,14 as did its predecessor and as does it successor,
prescribed general administrative procedures under section 1.446-
1(e), Income Tax Regs., for taxpayers to obtain the consent of
the Commissioner for changes in methods of accounting for Federal
income tax purposes. The revenue procedure provided, among other
things, rules for determining the appropriate period for taking
into account the section 481(a) adjustments relating to changes
in methods of accounting and under specified circumstances
required acceleration of the reporting of the section 481(a)
adjustment, including in the event that a taxpayer ceased to
engage in the trade or business to which the section 481(a)
adjustment related, on which occasion the taxpayer had to include
any unreported section 481(a) adjustment in income for the year
when trade or business ceased. See Rev. Proc. 84-74, secs. 5.06-
5.09, 1984-2 C.B. at 742-744.
We do not read the cryptic passage in the conference report
as a clear expression of congressional intent to restrict the
Commissioner's authority to compel acceleration of the 10-year
spread of a section 481(a) adjustment relating to a change in
method of accounting required under section 448(a) should a
14 Rev. Proc. 84-74, 1984-2 C.B. 736, which clarified,
modified, and superseded Rev. Proc. 80-51, 1980-2 C.B. 818,
effective for Forms 3115, Application for Change in Accounting
Method, filed for taxable years beginning on or after Oct. 29,
1984, Rev. Proc. 84-74, secs. 1, 11, 1984-2 C.B. at 737, 751, was
modified and superseded by Rev. Proc. 92-20, 1992-1 C.B. 685,
effective for Forms 3115 filed on or after Mar. 23, 1992, Rev.
Proc. 92-20, secs. 1, 14, 1992-1 C.B. at 688, 706.
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