Part III. Administrative, Procedural, and Miscellaneous

1.167(e)–1(a) and 1.446–1(e)(2)(ii)( b ) of the Income Tax Regulations.

.02 To obtain this consent, a Form 3115, Application for Change in Accounting Method, generally must be filed within 180 days after the beginning of the taxable year in which the proposed change is to be made. Section 1.446–1(e)(3)(i). .03 The Commissioner is authorized to prescribe administrative procedures setting forth the limitations, terms, and conditions as the Commissioner deems necessary to obtain consent for effecting a change in method of accounting and to prevent amounts from being duplicated or omitted, including the taxable year or years in which the § 481(a) adjustment is to be taken into account. Section 1.446–1(e)(3)(ii).

.04 In computing taxable income, § 481(a) of the Internal Revenue Code requires a taxpayer to take into account those adjustments necessary to prevent amounts from being duplicated or omitted when the taxpayer’s taxable income is computed under a method of accounting different from the method used to compute taxable income for the preceding taxable year.

.05 The basis of depreciable property is reduced by the amount of the depreciation allowed or allowable, whichever is greater. Section 1016(a)(2). .06 Unless otherwise provided in this revenue procedure, the terms ‘‘taxpayer’’, ‘‘year of change’’, and ‘‘filed’’ have the meaning given to them by sections 3.01, 3.03, and 3.04 of Rev. Proc. 92–20 (or any successor), respectively.