Prior section 754 election deadline extended by 60 days

Number

202521002

Outcome

Approved

Document type

Private Letter Ruling

IRS subject

Manner of Electing Optional Adjustment to Basis of Partnership Property under Section 754

Topics

Partnerships Late election relief (§ 9100)

Code sections

§ 754, § 6110

Ruling dated

February 14, 2025

Publicly released

May 23, 2025

Source

View Official PDF

Apply this to your situation

This page covers one taxpayer's ruling, issued in 2025, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.

About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.

View official IRS release (PDF)

Plain-English summary

The IRS had previously issued a private letter ruling concerning the taxpayer's deadline to file a section 754 election. This supplemental ruling does not restate the facts or analysis from the earlier letter. It extends the election-filing deadline to 60 days from the date of the supplemental ruling.

Ruling snapshot

Question: Will the IRS extend the filing deadline established in the earlier section 754 election ruling?
Outcome: Approved, with a new 60-day deadline
Key authorities: Prior PLR-118257-23

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury
Washington, DC 20224

Number: 202521002
Third Party Communication: None
Release Date: 5/23/2025
Date of Communication: Not Applicable
Index Number: 9100.15-00, 754.00-00
Person To Contact:
--------------------------------------------- -----------------------------------, ID No. -------
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-----------------
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Telephone Number:
----------------------------------------- -------------------- Refer Reply To:
CC:PT&E:B03
PLR-101628-25

Date:
February 14, 2025

Dear ----------------

This letter supplements PLR-118257-23, dated March 19, 2024 (Previous Letter).

The date to file the election referenced in the Previous Letter is extended to 60 days from the date of this supplemental ruling letter.

Sincerely,

Robert D. Alinsky
Branch Chief, Branch 3
Office of the Associate Chief Counsel
(Passthroughs, Trusts, and Estates)

Enclosures
Copy for § 6110 purposes

PLR-101628-25
2

Cc: -----------------------
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