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IRS National Office Memo Explains Why Change in Contribution Method Is Change in Acc'tng Method (PDF)
Internal Revenue Service [IRS]
[Official Guidance] Oct. 23, 2002
9 pages; IRS Chief Counsel Internal Legal Memorandum 200242001, 7/10/2002. Excerpt: 'Issue: Whether a change in the criteria used to determine the proper time for deducting contributions made to certain pension plans constitutes a change in method of accounting for purposes of §§ 446 and 481.' Although the memo concerns a pension plan, its reasoning sheds light on the reason the IRS issued Revenue Ruling 2002-73 concerning 401(k) plans with mismatched plan/taxable years.
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