Par. 5. Section 1.460-6 is amended by: 1. Adding paragraph (c)(3)(vii). 2. Redesignating paragraph (d)(2)(iv) as paragraph (d)(2)(v). 3. Adding a new paragraph (d)(2)(iv). The additions and revision read as follows:
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(c) * * *
(3) * * *
(vii) Section 481(a) adjustments. For purposes of determining the hypothetical underpayment or overpayment of tax for any year, amounts reported as section 481(a) adjustments shall be taken into account in the tax year or years they are reported. However, any portion of a section 481(a) adjustment not yet reported as of the tax year in which the contract is completed shall be taken into account in the tax year the contract is completed for purposes of determining the hypothetical underpayment or overpayment of tax.
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(d) * * *
(2) * * *
(iv) Section 481(a) adjustments. For purposes of determining the hypothetical underpayment or overpayment of tax for any year under the simplified marginal impact method, amounts reported as section 481(a) adjustments shall be taken into account in the tax year or years they are reported. However, any portion of a section 481(a) adjustment not yet reported as of the tax year in which the contract is completed shall be taken into account in the tax year the contract is completed for purposes of determining the hypothetical underpayment or overpayment of tax.
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