Taxpayers inherited a commercial property in 1985.  NO depreciation was ever taken by the owners.

Depreciation on a commercial property was over 31.5 years back then.   

This means the property (structure portion of course) would have been fully depreciated by now.   Would this fact be an issue in filing Form 3115 - that the change would yield a depreciation change of 100% (of the applicable basis) in one year?