The IRS today posted a redacted version of a field advice memorandum* concerning the application of the SRLY provisions after a reattribution election under Reg. section 1.1502-36(d)(6). 20150301F (release date January 16, 2015, and dated September 10, 2014)
*Field advice memo documents are prepared by IRS field attorneys in the Office of Chief Counsel, are reviewed by an Associate Office, and are subsequently issued to IRS field or service center employees. The memo cannot be used or cited as precedent.
In the field advice memo [PDF 133 KB], all of the facts presented are redacted. The IRS memo provides these conclusions:
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