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IRS PLR: Business Holdings Disposal Extension Granted to Private … – Bloomberg Tax

By Bloomberg Tax Automation
Private foundation (P), was granted an extension of five years under I.R.C. §4943(c)(7) for disposing of certain excess business holdings, the IRS ruled. P was created by Individuals, substantial contributors and disqualified persons with respect to P under §4946(a)(1)(A), to support the domestic and international community and various charitable organizations. Due to Individuals’ death, P received Entity 1 stock and Entity 2 membership interest from Trust (disqualified person under §4946(a)(1)). During the initial five-year period, P made diligent efforts to dispose of its excess business holdings. However, it wasn’t able to do so for a …
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