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F3115- Negative 481 adjustment

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    F3115- Negative 481 adjustment

    I know Form 3115 has been treated extensively in this forum, but wanted to double check a couple things I don't see specifically addressed. Client's prior tax return preparer never listed or amortized Goodwill ($285,000!) on the return. Should have been claimed since 2007. I'm preparing Form 3115 and wonder about the following:

    1) The negative adjustment is HUGE (-$132,269). Everywhere I read says a negative adjustment is taken in one year. This will cause an NOL. Is it really all to be taken in one year?
    2) DCN- Would this be code 7, impermissible to permissible, or code 78, amounts paid to acquire intangibles?
    3) Instructions for Schedule E on the f3115 state that the form is not to be filed "to make an election under section 167, 168, 197, or 1400l. Goodwill is section 197, therefore it would seem not to qualify for Form 3115...but I see no other way to address this mess. Am I missing something?

    I know everyone is terribly busy right now, so any insight is appreciated tenfold. Thank you very much.

    #2
    1) I think so. A positive adjustment can be spread out over 4 years, but I think a negative one is taken in one year.

    2) I would use 7.

    3) You are not making an "election", so that has no effect.

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