IRS PLR: Accounting Method Change Late Election Consent Denied (IRC §475)

“Taxpayer” (a husband and wife as a collective) in securities trading is not entitled to make a late election under tax code Section 475(f)(1) to apply the mark-to-market accounting method for a certain tax year, because it did not act reasonably and in good faith, and did not present unusual and compelling circumstances to except it from a conclusion that the sought relief would prejudice the interests of the government, the IRS ruled. Citing the timing of the request, the IRS said that Taxpayer stood to benefit from hindsight in determining the effect of the method change. According to ...