Federal Tax Day - Current, L.8, Code Sec. 7701: Entities Granted Extension to Make Entity Classification Elections (LTR 202634005, 202634009), (Aug 24, 2026)

Two entities were granted 120-day extensions to make entity classification elections under Code Sec. 7701. In the first case, the entity intended to be classified as an association taxable as a corporation whereas in the second case, the entity intended to be classified as a disregarded entity for federal tax purposes. However, the taxpayers inadvertently failed to file Form 8832, Entity Classification Election. In both the cases, the taxpayers satisfied the requirements of Reg. §§301.9100-1 and 301.9100-3; acted reasonably and in good faith. Therefore, granting relief did not prejudice the government’s interests.

IRS Letter Ruling 202634005

IRS Letter Ruling 202634009