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Posted by Stuart Bronstein on August 28, 2007, 4:29 pm
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>>> Where are these letter rulings? Can I find them at IRS.gov?
>>
>> Commerce Clearing House has all private letter rulings
>> available, indexed and cross-referenced. Check it out at
>> any law library.
> The "check the box" regulations made all those rulings
> obsolete. Now an LLC (or any unincorporated business
> association) can choose to be taxed as a corporation. If it
> does not elect corporate treatment, it will be treated as a
> partnership if it has more than one member. If it has a
> single member, it will be disregarded as an entity separate
> from its owner.
>
> So it doesn't matter how the IRS ruled on any particular
> state's LLC statute before Jan. 1, 1997 (the effective date
> of the new Reg. Sec. 301.7701-1 ff). Those rulings are of
> purely historical interest. Not worth a trip to the law
> library unless you are writing a historical treatise.
Excellent point. Sorry I didn't think of it first. ;-)
Stu
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