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    US Internal Revenue Service: rp-04-57

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    This document provides additional time and guidance for taxpayers to comply with requirements from Revenue Procedure 2004-23 related to changing accounting methods. It allows taxpayers to submit required written statements regarding accounting method changes by the date they file their tax return for the first or second year ending after December 31, 2003. It also treats taxpayers as meeting the timely filing requirement if recomputing their section 481(a) adjustment would not change the taxable income reported.

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    US Internal Revenue Service: rp-04-57

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    IRS
    36 views4 pages
    This document provides additional time and guidance for taxpayers to comply with requirements from Revenue Procedure 2004-23 related to changing accounting methods. It allows taxpayers to submit required written statements regarding accounting method changes by the date they file their tax return for the first or second year ending after December 31, 2003. It also treats taxpayers as meeting the timely filing requirement if recomputing their section 481(a) adjustment would not change the taxable income reported.

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    This document provides additional time and guidance for taxpayers to comply with requirements from Revenue Procedure 2004-23 related to changing accounting methods. It allows taxpayers to submit required written statements regarding accounting method changes by the date they file their tax return for the first or second year ending after December 31, 2003. It also treats taxpayers as meeting the timely filing requirement if recomputing their section 481(a) adjustment would not change the taxable income reported.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    36 views4 pages

    US Internal Revenue Service: rp-04-57

    Uploaded by

    IRS
    This document provides additional time and guidance for taxpayers to comply with requirements from Revenue Procedure 2004-23 related to changing accounting methods. It allows taxpayers to submit required written statements regarding accounting method changes by the date they file their tax return for the first or second year ending after December 31, 2003. It also treats taxpayers as meeting the timely filing requirement if recomputing their section 481(a) adjustment would not change the taxable income reported.

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    of 4

    Part III

    Administrative, Procedural, and Miscellaneous

    26 CFR 601.204: Changes in accounting periods and in methods of accounting.


    (Also Part 1, §§ 162, 263, 446, 461, 481; 1.167(a)-3(b), 1.263(a)-4, 1.263(a)-5, 1.446-1,
    1.461-4, 1.461-5, 1.481-1)

    Rev. Proc. 2004-57

    SECTION 1. PURPOSE

    This revenue procedure allows additional time for taxpayers to comply with the

    requirements of section 6.02 of Rev. Proc. 2004-23, 2004-16 I.R.B. 785. Section 6.02

    of Rev. Proc. 2004-23 requires certain taxpayers that seek to change to a method of

    accounting provided in §§ 1.263(a)-4, 1.263(a)-5, and 1.167(a)-3(b) of the Income Tax

    Regulations to submit a written statement containing information necessary to obtain

    automatic consent for the change.

    SECTION 2. BACKGROUND

    .01 On March 24, 2004, the Internal Revenue Service released Rev. Proc. 2004-

    23. Rev. Proc. 2004-23 provides procedures under which certain taxpayers may obtain

    automatic consent for the taxpayer’s first taxable year ending on or after December 31,

    2003, to change to a method of accounting provided in §§ 1.263(a)-4, 1.263(a)-5, and

    1.167(a)-3(b) of the Income Tax Regulations. As a term and condition of obtaining this

    automatic consent, taxpayers must file Form 3115, Application for Change in

    Accounting Method, and provide therein certain information specifically required by Rev.
    2

    Proc. 2004-23.

    .02 Section 6.02 of Rev. Proc. 2004-23 provides transition rules applicable to

    certain taxpayers that filed Form 3115 prior to April 26, 2004, and did not include in the

    Form 3115 all of the information required by Rev. Proc. 2004-23. In lieu of preparing

    and filing a new Form 3115, these transition rules permit taxpayers to prepare and file a

    written statement that includes all of the necessary information that was not included in

    the original Form 3115. Section 6.02(2) of Rev. Proc. 2004-23 requires taxpayers to

    submit the written statement, with an attached copy of page 1 of the original Form 3115

    filed by the taxpayer, to the national office within the timely filing requirements of section

    6.02(3)(a) (including the automatic extension period described in section 6.02(3)(b)(i)) of

    Rev. Proc. 2002-9, 2002-1 C.B. 327, as modified and clarified by Announcement 2002-

    17, 2002-1 C.B. 561, modified and amplified by Rev. Proc. 2002-19, 2002-1 C.B. 696,

    and amplified, clarified, and modified by Rev. Proc. 2002-54, 2002-2 C.B. 432.

    .03 Section 6.02(3) of Rev. Proc. 2004-23 requires taxpayers to attach the written

    statement and a copy of the original Form 3115 to the taxpayer’s federal income tax

    return for the taxpayer’s –

    (i) first taxable year ending on or after December 31, 2003, or

    (ii) second taxable year ending on or after December 31, 2003, if the taxpayer

    prior to April 26, 2004, has filed the taxpayer’s federal income tax return for

    the taxpayer’s first taxable year ending on or after December 31, 2003, that

    includes a Form 3115, a copy of which also has been filed with the national

    office, and the § 481(a) adjustment included on that return was computed

    correctly as described in section 5 of Rev. Proc. 2004-23.


    3

    SECTION 3. ADDITIONAL TIME TO SUBMIT WRITTEN STATEMENT

    .01 A taxpayer is treated as meeting the timely filing requirement of section

    6.02(2) of Rev. Proc. 2004-23 if the taxpayer submits the written statement referred to in

    section 6.02(2) of Rev. Proc. 2004-23, along with the attached copy of page 1 of the

    original Form 3115 filed by the taxpayer, to the national office at the special address

    provided in section 4.01(3) of Rev. Proc. 2004-23 on or before the time that the

    taxpayer files the federal income tax return referred to in section 6.02(3)(i) or (ii)

    (whichever is applicable) of Rev. Proc. 2004-23.

    .02 A taxpayer is treated as meeting the timely filing requirement of section

    6.02(3)(ii) of Rev. Proc. 2004-23 by attaching the written statement and a copy of the

    original Form 3115 to the taxpayer’s federal income tax return for the taxpayer’s second

    taxable year ending on or after December 31, 2003, if the taxpayer prior to April 26,

    2004, filed the taxpayer’s federal income tax return for the taxpayer’s first taxable year

    ending on or after December 31, 2003, that included a Form 3115, a copy of which also

    has been filed with the national office, whether or not the § 481(a) adjustment was

    computed correctly in the taxpayer’s federal income tax return for the taxpayer’s first

    taxable year ending on or after December 31, 2003, but only if computing the § 481(a)

    adjustment in accordance with section 5 of Rev. Proc. 2004-23 does not result in any

    change in the taxable income reported on that return.

    .03 For purposes of section 3.01 of this revenue procedure, section 6.02(3)(ii) of

    Rev. Proc. 2004-23 is applied after taking into account section 3.02 of this revenue

    procedure.

    .04 Sections 3.01 and 3.02 of this revenue procedure do not apply to a taxpayer
    4

    described in section 4.03(2) of Rev. Proc. 2004-23 (relating to an unauthorized change

    in method of accounting or change in the treatment of an item).

    SECTION 4. EFFECT ON OTHER DOCUMENTS

    Rev. Proc. 2004-23 is modified.

    SECTION 5. EFFECTIVE DATE

    This revenue procedure is effective on September 1, 2004.

    SECTION 6. INQUIRIES

    For further information regarding this revenue procedure, contact Grace

    Matuszeski of the Office of Associate Chief Counsel (Income Tax and Accounting) at

    (202) 622-7900 (not a toll free call).

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