30-Sep-2019 8:22am
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. Else we would not need that phrase in section 1221(a)(1), after the word "or".... property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business
30-Sep-2019 12:09pm
Terry Oraha wrote:The dmsh does not apply where inventory is concerned. In other words it’s not an option.
30-Sep-2019 12:19pm
Coddington wrote:Terry Oraha wrote:The dmsh does not apply where inventory is concerned. In other words it’s not an option.
That's not what the JCT Blue Book said.
30-Sep-2019 12:21pm
30-Sep-2019 12:22pm
30-Sep-2019 12:36pm
30-Sep-2019 12:50pm
Terry Oraha wrote:Coddington wrote:Terry Oraha wrote:The dmsh does not apply where inventory is concerned. In other words it’s not an option.
That's not what the JCT Blue Book said.
Are you saying that if the inventory is treated as materials and supplies then the DMSH could apply?
30-Sep-2019 1:00pm
30-Sep-2019 1:19pm
30-Sep-2019 1:57pm
30-Sep-2019 2:09pm
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30-Sep-2019 3:17pm
30-Sep-2019 3:35pm
Coddington wrote:I probably should have mentioned this before, but the TCJA changes, at most, take us back to pre-'86 law. Developers can't use section 471 for their "inventory", since it isn't merchandise. Since it isn't inventory under 471, they cannot elect NIMS treatment. Examples 17 and 18 of Rev Proc 2002-28 may be instructive in what is possible.
30-Sep-2019 3:45pm
30-Sep-2019 4:00pm
13-Oct-2019 6:19am
Coddington wrote:Developers can't use section 471 for their "inventory", since it isn't merchandise. Since it isn't inventory under 471, they cannot elect NIMS treatment. Examples 17 and 18 of Rev Proc 2002-28 may be instructive in what is possible.