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Did the IRS give more time for the missed QSub elections?
Cited answer
The IRS concluded that the taxpayer met the requirements for more time under §§ 301.9100-1 and 301.9100-3 to make QSub elections it had missed for six subsidiaries.1
Based solely on the facts submitted and representations made, we conclude that X has satisfied the requirements of §§ 301.9100-1 and 301.9100-3 with respect to the QSub elections for Sub 1, Sub 2, Sub 3, Sub 4, Sub 5, and Sub 9.
Issued to one taxpayer; not precedent (IRC § 6110(k)(3))
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