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The court noted that the fact that Vines had taken action against his first accountant makes it difficult to understand why he did not take similar action against his second accountant. The court did not expressly address this issue, but it is fair to assume that the court was suggesting that Vines should have taken action against his second accountant at the time he filed the suit, or within a reasonable time after filing the suit.
In a footnote, the court noted that the taxpayer was not required to file a Sec. 475 election, but failed to do so anyway. Thus, the taxpayer has lost the right to use the mark-to-market method of accounting.
If Arberg and Quinn had filed a Sec. 475 election, it would have been pointless. It is clear that the purpose of the election is to avoid the IRS using the mark-to-market method and potentially recouping the additional tax (and penalties and interest) that would have been paid.
The IRS has filed the NOI to prove that the IRS has determined that the sale of Arbergs and Quinns stock is a sale for profit and that it has assessed additional taxes, penalties, and interest against Arberg and Quinn. Arberg and Quinn have paid those amounts.[47] The IRS has not yet collected the additional taxes, penalties and interest.
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If a taxpayer fails to file a timely election, all is not lost. Regs. Sec. 301.9100-(3)(c) allows taxpayers to seek extensions for certain elections, including the election to use the mark-to-market method of accounting. As seen in the Vines 827ec27edc