IRS Issues PLR Granting Extension for Bonus Depreciation Opt-Out, Research Method Change

The IRS has issued a private letter ruling on Treas. Regs. §§301.9100-1 and 301.9100-3 and I.R.C. §§168 and 174 granting the taxpayer an extension of time to make an election under I.R.C. §168(k)(7) not to deduct additional first year depreciation for all qualified property placed in service during the taxable year and to file Form 3115 for a method change to comply with I.R.C. §174 for specified research or experimental expenditures. The taxpayer failed to timely file Form 7004 extension request for their consolidated federal income tax return after personnel turnover in their tax department caused a misunderstanding about filing ...