The IRS publicly released a private letter ruling* addressing the request of a taxpayer—a farmers cooperative organized as an agricultural marketing association—with respect to its loss in 2013 and the interaction between the tax rules for cooperatives under subchapter T and section 172, and the taxpayer’s plan for treatment of the loss. PLR 201536011 (release date September 4, 2015, and dated May 19, 2015)
In the letter ruling [PDF 73 KB], the IRS ruled that:
*Private letter rulings are taxpayer-specific rulings furnished by the IRS National Office in response to requests made by taxpayers and can only be relied upon by the taxpayer to whom issued. It is important to note that, pursuant to section 6110(k)(3), such items cannot be used or cited as precedent. Nonetheless, such rulings can provide useful information about how the IRS may view certain issues.
For more information, contact KPMG’s National Director of Cooperative Tax Services:
David Antoni | +1 (267) 256-1627 | firstname.lastname@example.org
Or Associate National Director of KPMG’s Cooperative Tax Services
Brett Huston | +1 (916) 554-1654 | email@example.com
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