IRS PLR Allows Taxpayer to Become QOF After Advisor Failed to Attach Form 8996 to Return

Monday, January 25, 2021 - 11:00am

A private letter ruling (PLR) by the Internal Revenue Service allowed a taxpayer to become a qualified opportunity fund (QOF) despite missing a registration deadline due to its tax advisor failing to attach IRS Form 8996 to the taxpayer’s return. Upon discovery of the oversight, the taxpayer directed the tax advisor to promptly submit a request for relief. In PLR 117194-20, the IRS said that the taxpayer acted reasonably and in good faith and the interests of the government would not be prejudiced by granting relief. A PLR is directed only to the taxpayer requesting it.