November 29, 2012
Private Letter Ruling on 663(b) Election
In PLR 201245008, the representative of a taxpayer's trust asked for an extension of time to make an election under § 663(b) of the IRC. That section of the IRC allows a taxpayer to an election that would treat the amount "paid or credited within 65 days of any taxable year to be treated as paid or credited on the last day of the preceding year." The PLR held that even though the taxpayer missed the deadline, "the IRS has discretion to permit extensions of up to six months where the taxpayer acted reasonably and in good faith." Here, the IRS concluded that the taxpayer did act reasonably and in good faith and that the failure to file timely was only an inadvertence.
See Conan Yuzna, PLR 201245008: Trust Granted 120-day Extension to Make 663(b) Election, Wealth Strategies Journal, Nov. 27, 2012.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.
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