USA Change of Method 3115 or Error Correction ?

Oct 4, 2022
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United States
Hello all-

I have two advisor CPA's which have a difference of opinion and frankly I am not sure which call is correct. One is of the opinion the issue is a change of method of accounting which requires filing of a 3115 in the next current tax year. The other feels it is correction of an error, not a change in method.

Here are the facts. In 2019 (still open for correction) an item which should have been capitalized as 39 yr property was instead expensed. It is not eligible for any safe harbor, 179 or bonus depn. 2020 and 2021 are being amended also so it is not an issue to correct by capitalizing and depreciating as it should have been in the first place. The company has a written capitalize policy to which this entry did not adhere. For tax purposes should this be viewed as a change in method and thus left incorrect and untouched in the 2019-21 amendments then corrected with a 3115 in the current year , OR treated as an error and corrected in the year of the issue (2019) and rolled forward through the following years? Thanks!

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