Supplemental ruling extended the corrective filing deadline to 60 days

Number

202524002

Outcome

Approved

Document type

Private Letter Ruling

IRS subject

Supplemental Inadvertent Termination Relief

Topics

S corporations

Code sections

§ 1362

Ruling dated

March 13, 2025

Publicly released

June 13, 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 supplemented and modified an earlier private letter ruling dated October 18, 2024. The public supplemental letter does not restate the facts or describe the underlying relief. It extends the deadline to file the elections and any original or amended returns required by the earlier ruling. Those filings are due within 60 days after the supplemental letter's date. Copies of both rulings must be attached to the elections and required returns.

Ruling snapshot

Question: How long does the taxpayer have to complete the elections and return filings required by the prior ruling?
Outcome: Approved
Key authorities: IRC § 1362, based on the IRS index classification; the supplemental letter does not restate the underlying authority

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury
Washington, DC 20224

Number: 202524002
Third Party Communication: None
Release Date: 6/13/2025
Date of Communication: Not Applicable
Index Number: 1362.04-00
Person To Contact:
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Telephone Number:
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Refer Reply To:
CC:PT&E:B03
PLR-103020-25

Date:
March 13, 2025

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

This letter supplements and modifies PLR-107710-24, dated October 18, 2024 (Previous Letter).

The date to file the elections and any original or amended returns for all open years consistent with the relief in the Previous Letter is extended to 60 days from the date of this supplemental ruling letter. A copy of the Previous Letter and this supplemental ruling letter should be attached to the election and any required returns.

Sincerely,

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

Enclosure
Copy for § 6110 purposes
PLR-103020-25
2

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