IRS Issues PLR Granting Partnership Extension to Make Late Basis Adjustment Election After Partner’s Death

April 6, 2026, 6:48 PM UTC

The IRS has issued a private letter ruling on I.R.C. §754 and Treas. Reg. §301.9100 granting a partnership 120 days to make a late §754 election for the year of a partner’s death, requiring basis adjustments to partnership property as if the election had been timely made. [PLR 202614026]

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