Private Letter Ruling 202244002, November 4, 2022
In a recent Private Letter Ruling, the Internal Revenue
Service granted a partnership 120 days from the date of the letter
to make an election under §754 of the Internal Revenue Code based
on a finding that it acted reasonably and in good faith, and that
granting relief would not prejudice the government's
interests.
The requesting partnership intended to make a §754 election
for its most recent taxable year. However, the partnership failed
to timely file such election with its partnership return for the
taxable year.
Section 754 provides, in part, that if a partnership files an
election, in accordance with the regulations prescribed by the
Secretary, the basis of partnership property is adjusted in the
case of a distribution of property, in the manner provided in
§ 734, and, in the case of a transfer of a partnership
interest, in the manner provided in § 743. Such an election
applies with respect to all
