Feb 1, 2006 12:00 PM

EXTENSION DENIED

From David T. Leibell and Daniel L. Daniels of Cummings & Lockwood LLC, in Stamford, Conn., we have this update:

  • IRS denies private foundation's request for five-year extension to dispose of excess business holdings. In Private Letter Ruling 200552018 (released Dec. 30, 2005), the Internal Revenue Service rejected the request of a private foundation seeking an additional five years to dispose of excess business holdings as defined in Internal Revenue Code Section 4943. The reason: the foundation had failed to provide a plan of disposition that could reasonably be expected to succeed by the end of any five-year extension period, as required by IRC Section 4943(c)(7).

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