Page 558 - Large Business IRS Training Guides

Acceleration Rules

• The new IRC § 451(c) and Rev. Proc. 2004-

34 provide if the taxpayer ceases to exist, the

taxpayer can no longer defer the recognition

of the income from the advanced payment for

tax purposes.

• Additionally, Rev. Proc. 2004-34 provides the

recognition of an advance payment when a

taxpayer’s obligation with respect to an

advance payment is satisfied or otherwise

ends.

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