IRS PLR: Extension of Time Granted to File Partnership Basis Election (IRC §754)

The IRS has published a private letter ruling on Section 754 and Treasury Regulation Section 301.9100 granting an extension of time to a limited partnership, classified as a partnership for federal tax purposes to elect to adjust the basis of partnership property. The extension was contingent on the company’s filings containing adjustments to the basis of its properties to reflect any Section 734(b) or 743(b) adjustments that would have been made if the Section 754 election had been timely made. [PLR 202524010]

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