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six-page letter outlining the reasons petitioner should qualify
for section 9100 relief to make the section 475(f) election for
the taxable year 2000. The letter also stated that petitioner
would file a formal private letter ruling request. Also enclosed
with the section 475(f) election and the six-page letter was a
“protective” Form 3115, Application for Change in Accounting
Method.
The Form 3115 stated that petitioner intended to adopt an
accounting method for his new securities-trading business, not
change an accounting method for an existing business. An
attachment to the Form 3115 stated in pertinent part:
The taxpayer desires to adopt a new method of
accounting for securities which are held in connection
with his trade or business as a trader in securities to
the mark to market method of recognizing gains and
losses as described in Section 475(f).
* * * * * * *
The taxpayer is not requesting any change in the
accounting methods used in his trade or business as an
attorney and since the year 2000 is his first year in
the trade or business of trading securities he is
adopting a mark to market accounting method with regard
to his trade or business of trading securities.
* * * * * * *
The taxpayer does not have to make any section 481(a)
adjustment because he was not engaged in the trade or
business of being a trader in securities prior to the
year 2000. He is adopting a mark to market method of
accounting for his trade or business as a securities
trader which did not begin until 2000.
* * * * * * *
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Last modified: May 25, 2011