IRS PLR: Partnership Basis Adjustment Election Extension Granted (IRC §754)

A limited liability company classified as a partnership (“X”) received extra time to elect to adjust the basis of partnership property under tax code Section 754, after inadvertently failing to do so with its timely filed return for the year at issue, in which an interest holder died. With such election, the IRS explained, basis is adjusted in the manner provided in Section 734 (distribution of property) or Section 743 (transfer of a partnership interest). The relief is contingent on X adjusting the basis of its properties to reflect any such adjustments that would have been ...