IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
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Late partnership basis-adjustment election (§ 754) allowed under 9100 relief
A limited partnership meant to make a section 754 election, which lets a partnership adjust the tax basis of its assets when interests change hands or property is distributed, so the incoming or affec…
IRS grants a partnership 120 more days to make a late Section 754 basis-adjustment election after a partner's death
A partnership asked the IRS for extra time to make a late election under Section 754 of the tax code, and the IRS agreed. A Section 754 election lets a partnership adjust the tax basis of its assets w…
IRS grants a lower-tier partnership 120 more days to make a late Section 754 basis-adjustment election after a partner's death
A partnership asked the IRS for extra time to make a late Section 754 election, and the IRS granted it. A Section 754 election lets a partnership adjust the tax basis of its assets when a partner dies…
IRS grants an LLC 120 more days to make a late Section 754 basis-adjustment election after new members bought in
A limited liability company taxed as a partnership meant to make a Section 754 election but missed the filing deadline. A Section 754 election lets a partnership adjust the tax basis of its assets whe…
Partnership receives 120 days to make a late section 754 election
A partnership failed to make a section 754 election after a deceased partner's interest passed to several successors. The IRS concluded that the partnership met the standards for discretionary relief …
Three partnerships receive 120 days to make late section 754 elections
Three related partnerships missed section 754 elections after deaths and transfers of partnership interests. The elections would have permitted basis adjustments to partnership property under sections…
Gain from repeatedly selling syndicated conservation easement LLC interests is ordinary income under section 1221
A promoter ran syndicated conservation easement (SCE) deals: it would buy into land-holding LLCs, subdivide the land, package interests into new LLCs, and sell those interests to investors who were pr…
Partnership gets 120 days to make a late Section 754 basis-adjustment election it meant to make on a buyout
When someone buys into a partnership (here an LLC taxed as a partnership), the partnership can elect under Section 754 to adjust the tax basis of its assets so the new partner's inside basis lines up …
Partnership received 120 days to make a late section 754 election
A partnership timely filed its return for the year in which a partner died, but it inadvertently omitted a valid section 754 election to adjust the basis of partnership property. The IRS found that th…
Partnership received 120 days to make a late section 754 election
A limited partnership missed a section 754 election for the year in which a partner died and the partner's interest was to pass to testamentary lifetime trusts. The partnership had relied on its retur…
A foreign partnership gets 120 more days to make the section 754 election it forgot to file with its return
A section 754 election lets a partnership adjust the tax basis of its assets when a partner's interest changes hands or when the partnership distributes property, so that the inside basis of the asset…
Partnership granted more time to make a late section 754 basis-adjustment election
A limited partnership got more time to make a section 754 election after its tax preparer inadvertently missed the deadline. A section 754 election lets a partnership adjust the tax basis of its prope…
Partnership granted extra time to make a late Section 754 basis-adjustment election after a partner's death
When a partner dies (or a partnership interest otherwise transfers), a partnership can make a § 754 election to adjust the basis of its assets so the new owner's inside basis matches what they effecti…
IRS grants a partnership extra time to make a late Section 754 basis-adjustment election
A Section 754 election lets a partnership adjust the tax basis of its property when it distributes property or when a partnership interest is transferred, so a partner's inside basis better reflects e…
IRS grants a lower-tier partnership extra time to make a late Section 754 basis-adjustment election
A Section 754 election lets a partnership adjust the tax basis of its property when a partner's interest transfers (including at a partner's death), so the new owner's inside basis matches what they p…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A lower-tier partnership gets 120 extra days to make a late § 754 basis-adjustment election
This is a companion ruling to another § 754 relief request on the same facts. A partner in an upper-tier partnership died, and the interest passed to his estate. A § 754 election lets a partnership ad…
A partnership gets 120 extra days to make a late § 754 basis-adjustment election
A partner in an upper-tier partnership died, and that partner's interest passed to his estate. A § 754 election lets a partnership adjust the inside basis of its assets when a partnership interest tra…
IRS grants a partnership 120 days to make a late § 754 basis-adjustment election
A partnership missed a Section 754 election and asked the IRS for permission to make it late. A Section 754 election lets a partnership adjust the tax basis of its property when a partner dies or a pa…
120-day extension for a partnership to make a late § 754 basis-adjustment election
A limited partnership wanted to make a § 754 election, which lets a partnership adjust the tax basis of its property when a partnership interest changes hands (here, when the sole beneficiary of a gra…
IRS grants a partnership 120 days to make a late Section 754 basis-adjustment election after a partner's death
A limited liability company taxed as a partnership asked the IRS for extra time to make a Section 754 election. That election lets a partnership adjust the tax basis of its property when a partner's i…
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 120 days of 9100 relief to make a late section 754 election
A limited liability company taxed as a partnership was supposed to make a section 754 election but missed the deadline. A section 754 election lets a partnership adjust the inside basis of its assets …
A partnership gets 9100 relief to make a late Section 754 election after a sale and redemption of partnership interests
A partnership went through a transaction in which some partners sold their interests to a buyer and the partnership redeemed the rest, and the purchase agreement called for the partnership to make a S…
A partnership gets 9100 relief to make a late Section 754 election after a sale and redemption of partnership interests
A partnership went through a transaction in which some partners sold their interests to a buyer and the partnership redeemed the rest, and the purchase agreement called for the partnership to make a S…
Partnership receives 120 days to make a late Section 754 election
A partnership intended to make a Section 754 election after a member died but inadvertently omitted a properly executed election from its return. The partnership and all affected partners filed their …
Partnership received 120 days to make a late Section 754 election
A partnership failed to make a Section 754 election after a partner died because it was unaware of the death when it filed its return. The election would permit basis adjustments to partnership proper…
IRS grants partnership late Section 754 election
A partnership failed to make a timely Section 754 election for the year in which a partner died. It represented that the failure was inadvertent, that it acted reasonably and in good faith, and that r…
IRS gives limited partnership more time for Section 754 election
A limited partnership timely filed its return for the year a partner died but inadvertently omitted a valid Section 754 election. The partnership represented that it acted reasonably and in good faith…
Partnership receives 120 days to make late Section 754 election
A limited liability company taxed as a partnership timely filed its return for a year in which partnership interests were transferred. It inadvertently omitted the Section 754 election that would adju…
Partnership gets 120 days for late Section 754 election
A partnership relied on its tax adviser but failed to make a Section 754 election after two partners died. The IRS found reasonable conduct, good faith, no hindsight, and no government prejudice, and …
Partnership gets 120 days for late Section 754 election
A partnership timely filed its return but omitted a Section 754 election after its tax preparers failed to advise it that an election was needed. The IRS found that the partnership acted reasonably an…
IRS grants extra time to make a late Section 754 basis-adjustment election
A limited liability company taxed as a partnership had a partner die during a tax year. That death transferred the partner's interest, a situation where a "Section 754 election" is valuable because it…
IRS grants a partnership extra time to make a late § 754 basis-adjustment election after a partner's death
A § 754 election lets a partnership adjust the tax basis of its assets when a partnership interest changes hands or property is distributed, so the new owner's inside basis matches what they effective…
Built-in-gain property leaving a § 721(c) partnership for a new foreign corporation is governed by § 367, with no separate § 721(c) gain
A U.S. corporate group set up a foreign partnership and contributed appreciated (built-in-gain) property to it. Because a U.S. member contributed that property to a partnership in which related foreig…
Partnership receives 120 days to make a late § 754 election
A limited liability company taxed as a partnership expected to redeem a deceased member's interest, so it did not make a section 754 basis-adjustment election for the year of that death. The interest …
Partnership acquisition cleared section 351 investment-company test
A publicly traded partnership planned to acquire an unrelated public corporation for partnership units and cash, after which the acquired corporation would contribute its assets to a lower-tier public…
Partnership gets 120 days to make late section 754 election
A limited partnership intended to make a section 754 election after a partner died and partnership interests passed through a trust. The partnership instructed its tax advisors to make the election, b…
LLC partnership gets late relief to make a Section 754 basis-adjustment election
A state limited liability company taxed as a partnership timely filed its return for the year in which interests were transferred, but inadvertently left off the election under IRC § 754. That electio…
Partnership joint venture gets late relief to make a Section 754 basis-adjustment election
A joint venture taxed as a partnership timely filed its return for the year in which partnership interests were transferred, but forgot to attach the election under IRC § 754. A § 754 election lets a …
Partnership receives time to make a late section 754 election
A limited partnership had partnership interests transferred during a tax year and timely filed its return, but inadvertently omitted the section 754 election. That election permits basis adjustments u…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.