IRS Issues PLR Granting Extension for Section 336(e) Election to Treat Stock Disposition as Asset Sale

The IRS has issued a private letter ruling on I.R.C. §336 and Treas. Reg. §301.9100 granting S Corporation Target, its shareholder, and purchasers a 60-day extension to enter into the required written agreement and file the election statement to treat a qualified stock disposition as an asset sale. [PLR 202614013]

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