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@vekesq wrote:

     My understanding is that catch-up depreciation is authorized for the year of change under Sec. 481(a).  However, Form 3115, Part IV, Section 481(a) Adjustment, line item 27, seems to limit the basis for the election to the two named.  (Please see below.)  

     How do I answer line item 27 if the only reason the client is taking catch-up depreciation is that he failed to take depreciation during the prior five years, and neither of the listed elections apply? 

     Thank you!

Line Item 27:

Is the applicant making an election to take the entire amount of the adjustment into account in the tax year of change?

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I think the correct answer is "no".  I think it is mandatory that a negative adjustment (you are claiming a deduction) is taken in full.  The "election" can apply if you are ADDING income to the tax return.