Even More IRS TPR Liveblogging

IRS is now clarifying what most of us took for a mistake in an answer by an IRS presenter at the previous presentation of this webinar. Shingles could be a capitalizable restoration or betterment in certain circumstances. But the replacement of just the shingles often would be a repair.

More liveblogging TPR Webinar

My first question gets answered re: RP 2015-20 and its presumptive use.  Merrill Feldstein says a post-2014 method change would be nonautomatic (until the expiration of the 5-year item eligibility rule) and that only 2014 and later costs would qualify.

To return to the possibility of the presumption being rebuttable, I think that many taxpayers will have a tough time demonstrating that the presumption does not apply. I have thoughts on how to do so, but can't cover while liveblogging.

Liveblogging the IRS TPR Webinar (Pt 3)

Jill El-Bendary of SBSE states that inventoriable items treated as nonincidental materials and supplies under Rev. Proc. 2002-28 are not eligible for the DMSH. The same applies to Rev. Proc. 2001-10.

Liveblogging IRS TPR Webinar (pt 2)

Merrill Feldstein of Chief Counsel says that taxpayers can amend returns back to 2012 to use the higher DMSH threshold if the DMSH was elected on the original return and the taxpayer had in place procedures at the beginning of that year to expense the item under its book policy (and did deduct it for book purposes).

IRS TPR Webinar - Liveblogging

The Service presenter just confirmed that if a taxpayer qualifies to use Rev. Proc. 2015-20 and did nothing, they will be presumed to have elected into its provisions.This isn't the worst case scenario, since the presumption would presumably be rebuttable. It just means that the taxpayer will have to pay for additional factual development to demonstrate that not only that it did nothing, but that it has not changed its methods of accounting if it wants to make a covered method change and take into account pre-2014 amounts in its section 481(a) adjustment.

New Automatic Change Form 3115 Mailing Address

On January 4th, 2016, the Service published Internal Revenue Bulletin 2016-1. This issue of the IRB contains Rev. Proc. 2015-1, which provides the general procedural rules for private letter ruling requests, accounting method changes, and other filings. Notable updates include:

• The nonautomatic accounting method application fee remains the same as last year: $8600.
• As anticipated based on the draft Form 3115 instructions, automatic method changes have a new mailing address:

          Internal Revenue Service 

          201 West Rivercenter Blvd.

          PIN Team Mail Stop 97

          Covington, KY 41011-1424  

• Rev. Proc. 2015-13 has been updated to change "Ogden copy" to "Duplicate copy".

        It is not clear whether accounting method change filers should use the new address yet. Section 18 of the revenue procedure provides that it is effective January 4th, 2016. The IRS Form 3115 website, however, has not yet been updated to reflect the new address. I have inquired about the filing address, but I suspect that we will not know the proper filing address until January 20th, during the Service's next TPR webinar.

Cumulative Bulletin Past Editions Available via GPO

PDF versions of the 1919-2008 Cumulative Bulletins are now available for free on the GPO website. Just search for <title:"Internal Revenue Cumulative Bulletin"> at the GPO website. How come the most important free resources seldom get mentioned?