Expanded relief available to make many elections

Article Abstract:

Regulation 1.9100-1 allows applications for relief to be filed in cases when taxpayers have failed to make timely elections. Under Reg 1.9100-1, extensions are granted at the discretion of the IRS if two conditions are met: if the relief application is filed within a reasonable period and if the extension does not prejudice the interests of the government. Interpretation of the provisions of Reg 1.9100-1 can be made with reference to Revenue Procedure 92-85, which is effective for all relief applications filed with the IRS as of Oct 1, 1992.

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Service warranty income and expense can be prorated

Article Abstract:

Revenue Procedure 92-97, IRB 1992-48, 7 states that the service warranty income method can be used in only two cases. These are when the first year in which warranty contracts advance payments are received coincide with the year the election is filed and when the taxpayer has employed an appropriate accounting method for advanced payments received. Under Rev. Proc. 92-97, the service warranty income method may be used by all retailers, wholesalers, and manufacturers of consumer goods.

Taxation, Insurance policies

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