![]() ![]() Accordingly, amended returns or claims for adjustment, based on a cost segregation study performed after the original return was filed (for the placed-in-service year), should generally be disallowed on the basis that the taxpayer is attempting to make a retroactive method change. The Service's historical position is that a change in computing depreciation under §§ 167, 168, 197, 1400I, 1400L(b), or 1400L(c), or former § 168 (“ACRS”) generally is a change in method of accounting under § 446(e) for which the consent of the Commissioner of Internal Revenue is required. However, this position was successfully challenged by several taxpayers in litigation with respect to depreciable property subject to § 168 (MACRS property). ![]() 78066 (December 28, 2006), address the circumstances under which a change in calculating depreciation or amortization is a change in method of accounting under § 446(e).Īs a result of these decisions, there was inconsistent treatment of taxpayers with respect to whether a change in computing depreciation under § 168 is a change in method of accounting under § 446(e).įinal regulations under § 446(e), T.D. The final regulations provide that the following are changes in method of accounting under § 446(e): These regulations adopt, with modifications, temporary regulations published in the Federal Register on January 28, 2004.
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