- 34 - 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 aPage: 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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