General Rule for Methods of Accounting (Permissible v. Not Permissible)

Office of Chief Counsel
Internal Revenue Service
Memorandum
Number: 200552010
Release Date: 12/30/2005
CC:ITA:B02:EBCleverdon
POSTF-150779-04
UILC: 446.00-00 date: September 09, 2005 to: John F. Risacher
Director of Field Operations
LMSB:HMT
477 Michigan Avenue
Detroit, MI 48226 from: Clifford M. Harbourt, Senior Technician Reviewer
Branch 2, Income Tax and Accounting subject: Technical Advice Memorandum Transmittal
Taxpayer/TIN: ---
CASE MIS No.: TAM-139427-04 Year(s) or Period(s) Involved: ---
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Attached is our memorandum in response to your request for technical advice in the case named above.
The attached memorandum comes within the scope of § 6110 of the Code and, accordingly, will be made open to public inspection in the Freedom of Information Reading Room, except in cases involving criminal investigations, civil fraud investigations, or jeopardy or termination assessments. This will normally occur 75-90 days after the date of mailing of the enclosed “Notice of Intention to Disclose” and the redacted copy of the technical advice memorandum to the taxpayer. These documents must be furnished to the taxpayer within 30 calendar days after the technical advice memorandum is mailed from the National Office, unless the IRS office to which the technical advice memorandum is addressed seeks reconsideration. The Notice of Intention to Disclose, Notice 438, must be appropriately dated in accordance with the instructions furnished by the National Office; the date of mailing of the Notice must be documented; and a copy of the Notice (containing the dates inserted by you) must be immediately forwarded with an accompanying transmittal memorandum containing the name of the taxpayer, to the National Office, c/o Chief, Disclosure Unit, CC:PA:T:DU, Ben Franklin Station, Post Office Box 7604, Washington, D.C. 20044.
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POSTF-150779-04 2
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Case returned for further development. State reasons below or continue on a separate sheet, if necessary.
Attachments: Distribution:
Copy of this memorandum You must check appropriate blocks.
Copies of this
Original and two copies of Technical
Advice memorandum and Technical Advice
Memorandum to:
Memorandum Operating Division
Copy of Technical Advice Memorandum edited for
SBSE XLMSB TEGE
WI
6110 purposes Appeals
Copy of Notice of Intention to Disclose Headquarters and Area Office
Copy of Technical Advice Dating
Schedule
WI LMSB SBSE-
TEGE
Submitting office case file (if any) Division Counsel
SBSE X LMSB TEGE
WI