IRS Provides Procedure to Obtain Permission to Make Late §1.469-9(g)(3) Real Estate Professional Rental Grouping Election

The IRS, responding to a spate of Tax Court cases and applications for private letter rulings seeking relief under the late election provisions of Reg. §301.9100-3, has provided a procedure (Revenue Procedure 2011-34) granting automatic late election relief to certain taxpayers who meet the real property business requirements of §469(c)(7) to make the election required [...]

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