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Strategies & Market Trends : VOLTAIRE'S PORCH-MODERATED -- Ignore unavailable to you. Want to Upgrade?


To: TimeToMakeTheInvs who wrote (35232)4/3/2001 4:58:06 PM
From: djia101362  Respond to of 65232
 
Tim-

I am currently looking into this and will let you know. I am also discussing this w/ a good friend that is a partner at a big 5 accounting firm.

Rev Proc 99-17, which provided the procedure for making this election, say..."If a taxpayer described in section 3 of this revenue procedure makes an election under section 5 of this revenue procedure, and the taxpayer's method of accounting for its taxable year immediately preceding the election year is inconsistent with section 475, the taxpayer is required to change its method of accounting to comply with its election. Section 6 of this revenue procedure contains procedures for effecting this change. A taxpayer that makes a section 475(e) or (f) election but fails to change its method of accounting to comply with that election is using an impermissible method."

The way I read this, although a 475(e) election is for the current year, it's telling you that you must go back and change the prior year, which is year 2000, to be consisent with the year for which the election is made, year 2001.

Again, double check w/ your own tax advisor but I'm going to do this for 2000 on my return. With the FED giving us the shaft, I'm am willing to take an aggressive return position which I believe there is substantial authority for.

To hell if I am going to have my cap losses out live me.