February 6, 2017 www.ipbtax.com

Reclassifying Section 174 Costs - Amended Returns versus Form 3115


The LB&I division of the IRS has just issued a Field Attorney Advice that represents the first time the IRS has confirmed in a publicly available document an IRS position from 1958 of which we have been advising our clients for some time relating to the available methodology for changing the treatment of certain costs for purposes of section 174.


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