IRS Issues PLR Granting Extension for Real Property Trade or Business Election

The IRS has issued a private letter ruling on I.R.C. §163 and Treas. Reg. §301.9100 granting taxpayer a 60 calendar day extension to make an election to be treated as a real property trade or business for purposes of avoiding the business interest deduction limitation under section 163(j), where taxpayer reasonably relied on a qualified tax professional who failed to inform taxpayer of the election availability despite having all necessary information to determine eligibility. [PLR 202618002]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.