Supplemental ruling extended corrective-return deadline to 240 days
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.
Plain-English summary
The IRS supplemented and modified a prior private letter ruling concerning S corporation shareholder eligibility, permitted trusts, and inadvertent termination relief. It replaced the prior ruling's legend and extended the time for the corporation, shareholder, and IRA to file all required original or amended returns. The parties received 240 days to file returns reflecting the shares as if the IRA had distributed them to the shareholder on the specified date.
Ruling snapshot
- Question: How was the prior inadvertent-termination ruling modified?
- Outcome: Relief approved, with 240 days to file corrective returns
- Key authorities: IRC §§ 1361, 1362
Full text (IRS public release)
Internal Revenue Service Department of the Treasury
Washington, DC 20224
Number: 202538012 Third Party Communication: None
Release Date: 9/19/2025 Date of Communication: Not Applicable Index Number: 1361.00-00, 1361.01-02, 1361.03-00, 1362.04-00 Person To Contact:
------------------------, ID No. -----------------
---------------------------------- Telephone Number:
------------------------- Refer Reply To:
------------------------------- CC:PT&E:B01
------------------------------------ PLR-111397-25
Date:
RE: ----------------------------------- June 25, 2025
Dear ---------------:
This letter supplements and modifies PLR-111847-24, issued January 24, 2025 (Previous Letter).
The legend of the Previous Letter is modified to read as follows:
X = ------------------------------------
-----------------------
Y = ------------------------------------
-------------------------
IRA = ------------------------------------
-----------------------
Date 1 = ---------------------
Date 2 = ----------------------
Date 3 = -----------------------
Date 4 = ------------------------
Date 5 = --------------------------
a = ---------
n = ---------------
PLR-111397-25 2
Additionally, pursuant to a letter sent from this office on May 19, 2025, X, Y, and IRA are granted an extension of time to file all required returns consistent with the relief provided in Previous Letter. Accordingly, the second paragraph of the Conclusion section of Previous Letter is modified to read as follows:
This letter is contingent on, within 240 days of the date of this letter, X, Y, and IRA filing with the appropriate service center any original or amended returns for the taxable year including Date 3 and all subsequent years and making adjustments to properly reflect the treatment of the a shares as if IRA distributed the a shares to Y on Date 3. A copy of this letter should be attached to each return.
In accordance with a power of attorney on file with this office, we are sending a copy of this letter ruling to your authorized representatives.
Sincerely,
__________
Laura Fields, Chief
Branch 1
Office of the Associate Chief Counsel
(Passthroughs, Trusts, and Estates)
Enclosures:
Copy for § 6110 purposes
cc: ----------------------------------
----------------------------------------
----------
--------------------------------
---------------------------
---------------------------------------
---------------------------
------------------------------------
What does the Code say today, for your facts?
This determination bound one taxpayer and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.
Opens in Ezel Pro.
- Checks the law as it stands today, not only this page
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace