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Rev. Proc. 2004-47, 2004-2, C.B. 169, provides an alternative method for certain…

Internal Revenue Bulletin 2025-1 · 2026-10-03 edition · updated 2026-10-04 · United States

obtain an extension of time to make a late reverse qualified terminable interest property election under § 2652(a)(3). Rev. Proc. 2004-47 also informs taxpayers who are denied relief or who are outside the scope of the revenue procedure of the information necessary to obtain a letter ruling.

Rev. Proc. 87-28, 1987-1 C.B. 770 (treating references to former § 162(k) as if they were references to § 4980B).

Bulletin No. 2025–1 101 December 30, 2024

7701 Relief for a late classification election for a newly formed entity

7701(a)(40) and 7871(d) Indian tribal governments and subdivision of Indian tribal governments

301.7701-2(a) Classification of undivided fractional interests in rental real estate

301.7701-3 Automatic extensions of time for late S corporation election and late corporate entity classification

301.9100-3 Extension of time to make entity classification election

7702 Closing agreement for failure to account for charges for qualified additional benefits

7702 Closing agreement for failed life insurance contracts

7702A Closing agreement for inadvertent non-egregious failure to comply with modified endowment contract rules

7704(g) Revocation of election

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▸Contents — Internal Revenue Bulletin 2025-1

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