Federal Tax Day - Current, L.2, Code Sec. 442: Entity Granted Relief for Late-Filed Form 1128 (LTR 202634003), (Aug 24, 2026)
An entity was granted relief to file Form 1128, Application To Adopt, Change, or Retain a Tax Year, to adopt a new tax year. Its tax advisor failed to timely file the form after becoming aware, shortly after the filing deadline, that the entity was required to change its taxable year to the majority interest taxable year. The entity acted reasonably and in good faith, and granting relief would not prejudice the interests of the government.
IRS Letter Ruling 202634003
Other References:
Code Sec. 442
CCH Reference - FED ¶20,406.10