joshuabarksatlcs
Level 10

The very last sentence of the current Reg. 1-446-1(e)(3)(i):

For any Form 3115 filed on or after May 15, 1997, see Section 1.446-1T(e)(3)(i)(B).

The referenced Temp Reg is no long there. 

True, you may say 3(i) could use some updating.  Call 60 Minutes.

 

That said, see Reg 1-446-1(e)(3)(ii):

(ii) Notwithstanding the provisions of paragraph (e)(3)(i) of this section, the Commissioner may prescribe administrative procedures under which taxpayers will be permitted to change their method of accounting. The administrative procedures shall prescribe those terms and conditions necessary to obtain the Commissioner's consent to effect the change and to prevent amounts from being duplicated or omitted. The terms and conditions that may be prescribed by the Commissioner may include terms and conditions that require the change in method of accounting to be effected on a cut-off basis or by an adjustment under section 481(a) to be taken into account in the taxable year or years prescribed by the Commissioner.

 

My take is that administrative procedures prescribed by the Commissioner over the years are clearly outlined in the applicable sections of the CURRENT Form 3115 instructions.  The referenced Temp Reg is by now passé.  So is the pdf you cited. 

I listed the JoA article to give a taste of the timeline of the key change. 

Over the years, a lot of water under the Form 3115 bridge.  Why do I worry about the taste of that water? 

I'd just go by the CURRENT Form 3115 instructions and march forward.    


I come here for kudos and IRonMaN's jokes.