Election to Deduct or Capitalize Certain Expenditures

ID:
Office:
UILC:
CCA_2012022811464343
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263.16-00
Number: 201221013
Release Date: 5/25/2012
From: ---
Sent: Tuesday, February 28, 2012 11:47:10 AM
To: ---
Cc: ---
Subject: RE: 2011-43 extrapolation
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It looks like you are scheduling a time to discuss this issue, which is good. I agree with your conclusion, however, that using extrapolation is not required to properly use the safe harbor method provided in Rev.
Proc. 2011-43. Use of the extrapolation procedures provided in Appendix A for purposes of calculating a § 481(a) adjustment amount is elective.
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