The IRS has issued a private letter ruling concerning Section 362, Treas. Reg. Sections 1.362 and 301.9100. This ruling grants the taxpayer an extension of time to file an election statement, as specified in Treas. Reg. § 1.362-4(d)(3)(i). The deadline for filing this statement is extended to 75 days from the date of the letter for the transfer of assets to the transferee corporation. The taxpayers were required to file U.S. tax returns for the relevant taxable years. [PLR 202529007]
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