IRS Issues PLR Granting Extension for Partnership Basis Adjustment Election after Partner’s Death

June 8, 2026, 1:56 PM UTC

The IRS has issued a private letter ruling on Treas. Reg. §301.9100 and I.R.C. §754 granting a partnership a 120-day extension to make an election for optional basis adjustments to partnership property following a partner’s death, requiring the partnership to file the election with Form 1065-X or Form 8082 and make retroactive basis adjustments reflecting what would have occurred if the election had been timely made. [PLR 202623009]

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