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200326013 Requested an extension of time under 3019100-1c of the Proc and Admin Regs for P to file t

200326013 Requested an extension of time under 3019100-1c of the Proc and Admin Regs for P to file t 2025

200326013 Requested an extension of time under 3019100-1c of the Proc and Admin Regs for P to file t Preview on Page 1

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The document is a Private Letter Ruling (PLR) from the Internal Revenue Service (IRS) regarding a request by a parent corporation (P) for an extension of time to file Forms 970, which are necessary for using the Last-In, First-Out (LIFO) inventory method for its subsidiaries (S1 and S2). The ruling outlines the circumstances under which P failed to file the required forms and confirms that P acted reasonably and in good faith. Consequently, the IRS grants a 30-day extension for filing these forms without prejudicing the interests of the government.

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Is 9100 relief a private letter ruling?

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.

What is the regulation section 301.9100-1?

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.

What is Section 444 election IRS?

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.

What is IRS Code Section 301.9100-2?

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.

What is the 301.9100 regulation?

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.

What is the relief under 301.9100-3?

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.

How do I get 9100 relief?

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.

200326013 Requested an extension of time under 3019100-1c of the Proc and Admin Regs for P to file t 2025

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