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Change in accounting method request does not qualify for audit protection.

The IRS has ruled in technical advice (TAM 200738014) that a service provider's request for a change in accounting method for mixed service costs does not qualify for audit protection because the service provider received written notification, citing the treatment of mixed service costs as an issue under consideration.

Facts

The taxpayer used an overall accrual method and a calendar tax year. On September 11,2003, the taxpayer submitted a Form 3115, Application for Change in Accounting Method, requesting permission to change its accounting method for self-constructed property under Sec. 263A. This Form 3115 was filed under the automatic consent procedures of Rev. ...

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