Thursday, January 10, 2013 9:33:41 AM
" ......Information, affidavits, and representations submitted by Parent, Company
Official, and Tax Professional explain the circumstances that resulted in the failure to PLR-128229-12 4
timely file a valid Election. The information establishes that Parent reasonably relied on
a qualified tax professional who failed to make, or advise Parent to make, the Election,
and that the request for relief was filed before the failure to timely make the Election
was discovered by the Internal Revenue Service. See §§ 301.9100-3(b)(1)(i) and (v).
Based on the facts and information submitted, including the affidavits submitted
and the representations made, we conclude that Parent has shown it acted reasonably
and in good faith, the requirements of §§ 301.9100-1 and 301.9100-3 are satisfied, and
granting relief will not prejudice the interests of the government. Accordingly, provided
the Parent Group qualifies substantively to file the Election, we grant an extension of
time under § 301.9100-3, until sixty (60) days from the date on this letter, for Parent to
file the Election........."
http://www.irs.gov/pub/irs-wd/1301009.pdf
Is this WMIH?
Feedback on this will be really appreciated
TIA
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