IRS PLR: Stock Sale Treatment as Asset Transfer Election Statement Filing Extension Granted (IRC §336)

Transactional parties received extra time to file a statement under Treas. Reg. §1.336-2(h)(3)(iii) complimenting an I.R.C. §336(e) election treating the purchaser’s acquisition (of an S corporation target) as a “qualified stock disposition” (Treas. Reg. §1.336-1(b)(6)) for no gain or loss recognition. The reasons for the failure to timely file the election statement were explained in submitted documentation. [PLR 202208008]

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