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Reg. 301.9100-1 through -3. The drawback is that unless he or she qualifies under the rules for automatic 9100 relief, the taxpayer is required to get a private letter ruling from the Service, which requires payment of a user fee.
301.9100-1, as revised, permits the Commissioner to grant relief to organizations that do not give timely notice under certain circumstances. Rev. Rul. 92-85, 1992-42 I.R.B.
Except as otherwise provided in this section, a partnership, S corporation, or personal service corporation may elect to have a taxable year other than the required taxable year.
Sections 301.9100-1 through 301.9100-3 provide the standards used to determine whether to grant an extension of time to make a regulatory election. Section 301.9100- 1(a). Section 301.9100-2 allows automatic extensions of time for making certain elections.
Section 301.91002 provides automatic extensions of time for making regulatory and statutory elections when the deadline for making the election is the due date of the return or the due date of the return including extensions.

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9100-3 Relief Standards for 501(c)(3) Applicants Section 301.9100-3(a) provides for other extensions of regulatory elections beyond the 27-month extension if the taxpayer acted reasonably and in good faith and the grant of relief will not prejudice the interests of the government.
In order to receive relief, it must be shown that the taxpayer acted reasonably and in good faith and that granting relief will not prejudice the interests of the government. If the taxpayer meets these criteria to the satisfaction of the IRS, relief may be granted.