SECTION 13. SUCCESSOR IN

INTEREST

.01 In general . Except as otherwise provided in this section 13, a Capacity Limitation allocation award applies only to the taxpayer who applied for and received an allocation award for the facility the taxpayer owns. If a taxpayer wants to request a transfer of an allocation, it should refer to DOE’s publicly available written procedures to initiate a transfer request in the Portal. Transfer requests will be reviewed and approved by the IRS. The IRS intends to provide future guidance regarding unin

corporated organizations that elect to be excluded from the application of subchapter K.

.02 Additional Selection Criteria . Applicants who received an allocation based on the Additional Selection Criteria should refer to § 1.48(e)-1(m)(5) regarding potential disqualification if the original applicant does not retain the requisite interest described in § 1.48(e)-1(m)(5) in an entity treated as a partnership for federal income tax purposes that owns the facility.