Ezel / IRS Rulings / 1043037
Chief Counsel Advice 1043037 Released October 29, 2010 Advice

Advance notice matters for accounting-method changes

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This page covers one taxpayer's ruling from 2010, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2010
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
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Plain-English summary

Chief Counsel responded to a question about Form 3115 and the advance-notice requirement for an accounting-method change. The advice does not identify a specific Form 3115 conclusion, but points to discussions of IRC § 446(e) recognizing the significance of advance notice. It cites Capital One, 130 T.C. 147, 154-55.

Ruling snapshot

  • Question: What guidance addresses the significance of advance notice for a Form 3115 accounting-method change?
  • Outcome: Advice given
  • Key authorities: IRC § 446(e); Capital One, 130 T.C. 147

Full text (IRS public release)

ID: CCA-816303-10 Number: 201043037
Release Date: 10/29/2010
Office: -------------
UILC: 446.04-02

From: -----------------------
Sent: Monday, August 16, 2010 3:03 PM
To: -------------
Cc: -----------------------------
Subject:

I don't know anything off the top of my head that is specific to the Form 3115, but there are a number of discussions of 446(e) that acknowledge the significance of advance notice. See, e.g., Capital One, 130 T.C. 147, 154-55.

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