The regulations may provide that income realized before the change date from discrete sales of assets would be excluded from the ratable
allocation and could be offset without limit by pre-change losses.
The regulations maintain the general rule of ratable
allocation but allow for a closing of the books election made on a timely filed return.
Thus, it makes no sense to attempt to determine the ratable
share of E&P in a corporation in which the shareholders do not have any stock ownership.
382 limitation while, under ratable
allocation, some portion of the loss would be allocated to the prechange period and subject to limitation.
736(b) payments to be made to a partner is fixed, however, the partner may determine the amount of gain or loss attributable to each payment by applying a ratable
portion of his basis in the partnership interest to each payment.
Payment method: The payment method applies to all taxpayers that have not elected the ratable
accrual method and that have not elected the recurring item exception.
It will be important to identify at the top of the statement, "REQUEST TO CHANGE TO THE RATABLE
ACCRUAL METHOD FOR REAL PROPERTY TAXES UNDER REV.