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SECTION 6. APPEALS AND COUNSEL FOR THE GOVERNMENT DISCRETION TO RESOLVE TIMING ISSUES

Internal Revenue Bulletin 1998-22 · 2026-10-03 edition · updated 2026-10-04 · United States

.01 Authority to resolve timing issues .02 Types of resolutions

(1) In general (2) Accounting method change with compromise terms and conditions

(a) Treating a timing issue as a method change (b) Requirement to apply the law to the facts (c) Using a § 481(a) adjustment or cut-off method (d) Terms and conditions of change (3) Alternative timing (4) Time-value of money

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