IRS PLR: Extension Granted for Election Regarding Basis of Transferred Stock (IRC §362)

The IRS has published a private letter ruling on Section 362 and Treasury Regulation Sections 1.362 and 301.9100 granting an extension of time for a taxpayer to file a Section 362(e)(2)(C) Statement regarding a stock transfer, in the manner described in Treasury Regulation Section 1.362-4(d)(3), and filing the Section 362(e)(2)(C) Statement with an amended return for the taxable year in which the transfer occurred. The extension was conditioned on the federal tax liability of any relevant party not being lower, in the aggregate, for all years to which the Section 362(e)(2)(C) election applies, than it would have been if the ...