Research Problem 2. Emerald Corporation must change its method of accounting for Federal income tax purposes. The change will require that an adjustment to income be made over three tax periods. Jonas, the sole shareholder of Emerald, wants to better understand the implications of this adjustment for E & P purposes, as he anticipates a distribution from Emerald in the current year. Prepare a memo for your firm’s files describing the results of your research.

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§ 481(a).

Rev.Proc. 97–27, 1997–1 C.B. 680.