ADMINISTRATIVE

Rev. Rul. 2004–88, page 165. TEFRA partnership; disregarded entity; pass-thru part- ner; tax matter partner. This ruling addresses whether a disregarded entity partner will disqualify a partnership from being a “small partnership” excluded from the TEFRA partnership provisions. The ruling also addresses whether a disregarded entity may be designated as the tax matters partner of a partnership.

Rev. Proc. 2004–48, page 172. This document provides that certain eligible entities may request relief for a late S corporation election and a late election to be classified as an association taxable as a corporation within 18 months of the original due date of the S corporation election (but in no event later than 6 months after the due date of the tax return, excluding extensions, for the first year the entity intended to be an S corporation).

August 9, 2004 2004–32 I.R.B.