Rental real estate: Where taxpayers showed good faith, IRS granted extension to treat all their interests in rental real estate as single rental real estate activity (PLR 200851001). This is good news for taxpayers, but an expensive and risky way to go about it. Better to just make the election on the tax return.
S-Corporation: IRS allowed continued treatment as an S-corporation even though stock was issued to stock to LLC/ineligible shareholder, ruling that the action was inadvertent (PLR 200851008).
S-Corporation: IRS did not allow a corporation to re-elect S-corporation status before the 5-year post-termination period was up (PLR 200851003).
S-Corporation: IRS continuing to allow late S-corporation elections where reasonable cause can be shown (PLR 200851015; PLR 200851022).
Trust: Trust disregarded and self-employment tax imposed on distributions where trusts lacked economic substance (Alfred J. Olsen, et ux. v. Commissioner, TC Memo 2008-275).
Estate: Estate allowed to deduct attorney's fees for estate administration, although attorney's papers were sloppy and record was otherwise “thin” (Estate of Thelma G. Hurford v. Commissioner, TC Memo 2008-278.
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