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The IRS examining agents argued that the taxpayer was not allowed to file its request for change in accounting method because the treatment of royalty expenses under Sec. Club owners First Leisure had talked about re-opening the club, which closed last May, if their request for change of use was refused. Also eliminated are the many rules regarding the time in which a request for change in an accounting method (Form 3115, Application for Change in Accounting Method) can be filed. |
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