IRS Issues PLR Granting Extension for Partnership Basis Election, Requiring Basis Adjustments

The IRS has issued a private letter ruling on I.R.C. §754 and Treas. Reg. §301.9100 granting a partnership a 120-day extension to file a Section 754 election using Form 1065-X or Form 8082 after inadvertently failing to make the election following a partner’s death, requiring the partnership to adjust property basis to reflect Section 734(b) or Section 743(b) adjustments and affected partners to reduce their partnership interest basis by additional deductions that would have been allowable with a timely election. [PLR 202624007]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.