Ruling Request under Rev Proc 2014

Technical topics regarding tax preparation.
#1
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1
Joined:
18-Jun-2014 4:40am
Location:
Israel
I need to file a request for a PLR re: client's failure to make a timely check-the-box election to be treated as a disregarded entity but I am having trouble finding sample language for 1) reasons for expedited handling and 2) reasonable cause for the late filing.

Could anyone who has successfully drafted language for 1 and 2 please provide some sample language?

Thanks so much!
 

#2
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3255
Joined:
9-Jun-2014 4:10pm
Location:
Coastal California
Intl Taxpayer wrote:I am having trouble finding sample language for... reasonable cause for the late filing.


Reasonable cause is not a matter of "language." What exactly WAS the reason?
 

#3
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543
Joined:
22-May-2014 1:38pm
Location:
Texas
What was the entity defaulted to be? Single Member LLCs are defaulted to disregarded without an election.
 


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