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 the taxpayer an extension of time to elect to adjust the basis of partnership property. The extension is 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 election had been made in a timely manner. [PLR 202521005]

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