IRS PLR: Mixed Straddle Election Extension Granted (IRC §1092)

A partnership in the business of trading in securities received extra time to make a mixed straddle election under Treas. Reg. §1.1092(b)-4T(f)(1), having shown reasonable cause for failing to timely do so. A third-party accountant senior employee who prepared Taxpayer’s Form 6781, Gains and Losses From Section 1256 Contracts and Straddles, as part of a filing for a tax return extension, mistakenly assumed that the absence of a checkbox in an expected place in software (unaware that the box was relocated after tax law changes) meant that the form would be automatically attached to the filing with ...