IRS corrects facts but preserves Form 8300 conclusion

Plain-English summary

This letter modifies a prior ruling about Form 8300 reporting by correcting how the taxpayer handled the form. The corrected fact states that a store manager prepared and signed Form 8300 for the entity, then submitted it to the entity for filing with the IRS. The correction did not change the earlier conclusion that the taxpayer was not required to file Form 8300. The letter provides no further substantive analysis.

Ruling snapshot

• Question: Did the factual correction change the prior conclusion about Form 8300 reporting?
• Outcome: Approved: no, the no-reporting conclusion remains unchanged.
• Key authorities: IRC § 6050I

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury
Washington, DC 20224

Number: 202118001
[Third Party Communication:
Release Date: 5/7/2021
Date of Communication: Month DD, YYYY]
Index Number: 6050I.00-00
Person To Contact:
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Telephone Number:
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Refer Reply To:
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CC:PA:01
PLR-102268-21
Date:
February 02, 2021

Dear ---------------:

This letter modifies and corrects the ruling issued to your office as PLR-112182-20 on December 17, 2020. The ruling issued on December 17, 2020, contains an inaccurate statement with respect to the facts of the actions of the taxpayer when preparing Form 8300. The corrected statement appears in the third paragraph and reads:

The store manager prepares and signs Form 8300 on behalf of Entity 2 as the recipient of the cash and submits it to Entity 2, which files it with the IRS. See Publication 1544.

The result of the ruling, that the taxpayer is not required to file Form 8300, is unchanged. This modification letter, as well as the private letter ruling it modifies, is directed only to you, the taxpayer who requested it. Section 6110(j)(3) of the Code provides that such letters may not be used or cited as precedent.

Sincerely,

Pamela Wilson Fuller
Senior Technician Reviewer
Procedure & Administration

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