IRS GRANTS EXTENSION TO ELECT FOR TREATMENT AS PURCHASER

Tuesday, July 17, 2012 - 7:15am

The Internal Revenue Service (IRS) last week released Private Letter Ruling (PLR) 201228019, granting the taxpayer in question an extension to file the election, for purposes of the historic tax credit program, under Treasury Regulation 1.48-4 to treat the tenant as having purchased the property. In this case, the taxpayer’s accountant did not treat the building as placed in service in the appropriate year and did not attach the election to the taxpayer’s federal income tax return, although the agreement was attached to the lease and other documents. The ruling allows this taxpayer to file an amended tax return with the appropriate election and the election will be considered as timely filed. PLRs are directed to the taxpayers who requested them and may not be used or cited as precedent. 

Discuss this and other news of significance to historic tax credit practitioners at Novogradac & Company’s National Historic Tax Credit Conference, September 6-7 in Louisville, Ky.National Historic Tax Credit Conference