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to prescribe the cessation-of-business acceleration provision as
a condition to obtaining consent to a change in method of
accounting and a spread of the resulting section 481(a)
adjustment). Accordingly, we conclude that the presence of a
cessation-of-business acceleration provision in Rev. Proc. 84-74
does not render section 1.448-1(g)(3)(iii), Income Tax Regs.,
inconsistent with section 448(d)(7)(C).
Additionally, we conclude that requiring the Category B
Corporations to include the entire balance of the section 481(a)
adjustment in income for 1987 is within the scope of section
1.448-1(g)(3)(iii), Income Tax Regs. The cessation-of-business
acceleration provision contained in the regulations is applicable
whenever a "taxpayer has ceased to engage in the trade or
business to which the section 481(a) adjustment relates" prior to
the end of the adjustment period. The determination as to
whether a taxpayer has ceased to engage in the trade or business
to which the section 481(a) adjustment relates, or has terminated
its existence, is made under the principles of section 1.446-
1(e)(3)(ii), Income Tax Regs., and its underlying administrative
procedures. Sec. 1.448-1(g)(3)(iii), Income Tax Regs.
Respondent has taken the position that where a corporation
maintains different divisions for each trade or business and one
of the divisions ceases to engage in its trade or business, the
corporation ceases to engage in that trade or business and,
therefore, must include in income any remaining portion of a
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