Thanks in advance for helpful experience.
Form 8832 has *not* been filed apparently; the entity was incorporated in September 2003. Does anyone have experience with a late filed 8832 approval?
In particular, does anyone have experience with Private Letter Ruling requests and could offer advice as to what to emphasize? Thanks again!
-shannon
Just what are you trying to accomplish with it? if it pertains to subchapter S corp, then let me know. ChEAr$, Harlan Lunsford, EA n LA
I would try taking advantage of the relief granted in Rev Proc 2002-59 before going for a letter ruling. See the instructions for Form 8832. A letter ruling is a very expensive proposition. The IRS fee alone is $9,000. You'll also need to figure in the professional fees you are going to need to help you draft the ruling request and to deal with the IRS if they have any questions.
--Chris
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