- 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 Proc. 84-74, 1984-2 C.B. 736, which clarified, modified, and superseded Rev.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 Proc. 84-74, secs. 1, 11, 1984-2 C.B. at 737, 751, was modified and superseded by Rev.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.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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