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the citation of section 475(f) from Dr. Sullivan and relayed it
to Mr. Sellers.
Mr. Sellers informed petitioner that, according to Rev.
Proc. 99-17, 1999-1 C.B. 503, in order for a section 475(f)
election to be effective for the 2000 taxable year, petitioner
had to file the election by April 17, 2000, the due date for his
1999 tax return. Mr. Sellers then informed petitioner that he
should qualify for an extension of time within which to make the
section 475(f) election under section 301.9100-3, Proced. &
Admin. Regs. (section 9100 relief).
Petitioner hired the Washington, D.C., law firm of Caplin &
Drysdale to prepare and file the section 475(f) election and
request for section 9100 relief. On July 21, 2000, Caplin &
Drysdale, on behalf of petitioner, submitted to respondent a
“Taxpayer Election of Mark to Market Accounting Under Section
475(f)” (section 475(f) election), along with a six-page letter
outlining the reasons petitioner should qualify for section 9100
relief. 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
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