The IRS has issued a private letter ruling on section 754 granting taxpayer a 120-day extension to file an election under section 754 for its taxable year ending on Date 3. Taxpayer must file the election in a written statement accompanying Form 1065-X, Amended Return or Administrative Adjustment Request (AAR), or Form 8082, Notice of Inconsistent Treatment or AAR, for the taxable year ending on Date 3. [PLR 202535006]
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