Extension of Time for Making Certain Elections

ID: CCA_2011051217270926 Number: 201125019
Release Date: 6/24/2011
Office: ---
UILC: 9100.00-00
From: ---
Sent: Thursday, May 12, 2011 5:27:13 PM
To: ---
Cc:
Subject: A different question
First I am assuming your taxpayer is not abroad. Second, I do not concur that the taxpayer's attempted election comes under the automatic 6-mos. extension provision (section 301.9100-2(b)). The taxpayer did not file its return or request the election within 6 months of the due date of the return if you don't take into account extensions. The taxpayer would have to qualify for 9100 relief under 301.9100-3, which is not that easy to do. I do agree that the election to use installments under section 6166 is the type of election that could be extended under the general provisions of 9100 though. ---