- 7 - reason of the change in order to prevent amounts from being duplicated or omitted”. Sec. 481(a)(2). If there has been a change in method of accounting, then section 481(a) applies and adjustments are made thereunder to prevent the omission or duplication of taxable income caused solely by the change in method of accounting. If there has not been a change in method of accounting, then no adjustment pursuant to section 481(a) is made. A change in method of accounting to which section 481(a) applies includes “a change in the overall method of accounting for gross income or deductions, or a change in the treatment of a material item.” Sec. 1.481-1(a)(1), Income Tax Regs. Regulations promulgated under section 481(a) incorporate the rules of section 446(e) and section 1.446-1(e), Income Tax Regs., for determining when a change in method of accounting has occurred. Sec. 1.481-1(a)(1), Income Tax Regs. A change in method of accounting “includes a change in the overall plan of accounting for gross income or deductions or a change in the treatment of any material item used in such overall plan.” Sec. 1.446-1(e)(2)(ii)(a), Income Tax Regs. A material item, in turn, “is any item which involves the proper time for the inclusion of the item in income or the taking of a deduction.” Id.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011