IRS PLR: 120-Day Extension Granted to Make Late Election for Optional Adjustment to Basis of Partnership Property (IRC §754)

The IRS has published a private letter ruling on I.R.C. §754 and Treas. Reg. §301.9100, granting a partnership a 120-day extension to make a late §754 election, effective for the taxable year, and contingent on filing appropriate adjustments to partnership property basis reflecting §734(b) or §743(b) adjustments that would have occurred with a timely election. [PLR 202551028]

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