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Posted by cballard@tyyni.net on August 10, 2007, 2:03 am
Please log in for more thread options sumtaxsoluti...@hotmail.com wrote:
> 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?
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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