Company Gets Extension To File a Section 754 Election To Adjust Basis of Partnership Property

Regulations for section 754 provide a deadline for companies to elect to adjust the basis of partnership property. The IRS granted a company an extension to file this election in Private Letter Ruling 201149008. The IRS will consider an extension if the taxpayer acts in good faith and reasonably and if the extension does not “prejudice the interests of the Government.”

See PLR 201149008 (Aug. 22, 2011); see also Andrew Hodes, PLR 201149008: IRS Grants Extension to File a Section 754 Election to Adjust Basis in Partnership Property, Wealth Strategies Journal, Dec. 16, 2011. 

Special thanks to Jim Hillhouse (WealthCounsel) for bringing this article to my attention.