The memorandum addresses whether a change in accounting method occurs when a taxpayer no longer treats certain securities transactions as options and the implications of IRC § 481(a) adjustments. It concludes that a change in accounting method does occur, requiring adjustments to eliminate distortions caused by the change. The document discusses the taxpayer's deferral of gains, losses, income, or deductions associated with Basket Transactions and the IRS's challenge to this deferral, proposing a new accounting method consistent with the taxpayer's ownership of the securities.
documents/EFTA01193903.pdf
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