The IRS has issued a private letter ruling on Treas. Reg. §301.9100 and I.R.C. §382 granting Taxpayer a 75-day extension to file a closing-of-the-books election under Treas. Reg. §1.382 for an ownership change that affected its ability to offset post-change taxable income with pre-change losses. [PLR 202614017]
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