IRS Issues Private Letter Ruling Granting Partnership Extension to Make Late Basis Adjustment Election After Partners’ Deaths

March 9, 2026, 3:44 PM UTC

The IRS 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 effective for its tax year after the death of two partners, requiring basis adjustments to partnership properties reflecting §734(b) or §743(b) adjustments as if timely made. [PLR 202610009]

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