- 4 - originally changed their accounting method. The RRA provided that petitioners had to include the 1997 deduction in income by making section 481 adjustments ratably over the next 4 taxable years. RRA sec. 7003(c)(2)(C), 112 Stat. 833. Petitioners properly reported the ratable portions of the section 481 adjustment as income on the returns for 1998 and 1999. Before petitioners could fully include the remaining section 481 adjustments in income over the next 2 years, MMC elected to be treated as an S corporation commencing with the 2000 taxable year. The subsidiaries that had previously been consolidated with MMC also elected to be treated as S corporations commencing with the 2000 taxable year. Tax Returns for 2000 and 2001 MMC reported the section 481 adjustment as income on the S corporation tax returns for the years at issue but did not report the section 481 adjustment as recognized built-in gain pursuant to section 1374 for either year at issue. Respondent examined the returns for the years at issue and issued a deficiency notice determining that petitioners should have included the section 481 adjustment income as recognized built-in gain under section 1374 and were therefore liable for additional built-in gain tax for the years at issue. Petitioners timely filed a petition.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: March 27, 2008