Moreover, since the alternative-timing procedure resolves accounting method change issues on a non-accounting-method-change basis, this section of the proposed procedure should be clarified to state that, pursuant to the closing agreement, Exam is precluded from proposing a [sections] 481(a) adjustment in later audit cycles for the same issue.
Section 10 also asserts, without reasoned justification or legal support, that the IRS may ignore the statute of limitations in respect of improperly deducted capital expenditures (or any other "timing" item adjustment) relating to noninventory property in any prior year merely by proposing a [sections] 481(a) adjustment in the earliest open tax year under examination.
For instance, OIG is proposing that the seller inform the buyer in an effective manner of its obligation and refrain from doing anything that would impede the buyer's ability to meet its reporting obligations.
OIG is proposing to allow sellers to provide discounts - other than forgiveness of deductibles and coinsurance - directly to beneficiaries.
Moreover, DOE is proposing
that $75 million already appropriated for these programs in FY '87 be rescinded to match the lower amounts requested in the new budget.
Riordan also is proposing
a raise for the city's Cultural Affairs Department General Manager Adolfo Nodal, whose salary would go from $84,439 to $93,313.
Specifically, EPA is proposing
and seeking public comment on two options: (1) Advanced Wastewater Treatment with Non-Endangerment Demonstration
GSM not declaring, paying or making or proposing
to declare, make or pay any bonus, dividend or other distribution in respect of its share capital;
TEI submits that, in proposing
that the regulations be effective in respect of rate orders made final 30 days or more following the issuance of the regulations, the IRS did not fully take into account that considerable time may lapse between the issuance of an order by a regulatory commission and a final determination within the meaning of the regulations.
They will, after all, b used by the IRS as a basis for proposing
Thus, 8-1/2 months may well be the "shorter" of the two standards set forth in the statute, and the IRS erred in proposing
a rule effectively stating it will always be the longer of the two.