- 4 - given power of attorney on behalf of NTI at the time the Form 2553 was initially received by respondent. On or about March 14, 1991, the Form 2553 was sent by regular mail to respondent's Memphis Service Center (the Service Center). It was received on March 18, 1991, as evidenced by a date stamp placed on the document at the Service Center. NTI intended the election to be effective beginning January 1, 1991; however, the designated area on the Form 2553 where the effective date should have been filled in (box D) was left blank. Also left blank was the designated area for NTI's employer identification number (box A). With respect to an incomplete Form 2553, in April 1991 section 3(13)2(34).(14) of the Internal Revenue Manual provided: (1) If the election is incomplete or eligibility cannot be determined, correspond via Letter 312C. Allow 30 days for the taxpayer's response. Annotate all actions on the case file, suspend the case. (2) TIMELY RESPONSE--If the reply to complete the election is received within the filing period or within 30 days, accept the election for the period requested. (3) LATE RESPONSE--If the reply to complete the election is received after the filing period and after the 30 day period, but before the 16th day of the third month of the following year, accept the election for the following year. (4) NO REPLY--If a reply is not received at the end of the suspense period, annotate the case file "No Reply". * * *. Send the taxpayer a letter explaining why Form 2553 was rejected. (5) If the reply is received after the 16th day of the third month of the following year, or the reply is incomplete, reject the election. * * *.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011