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5h.5(a)(2) of the Temporary Tax Reform Act of 1986 Election
Regs., 52 Fed. Reg. 3626 (Feb. 5, 1987), provides,
(a)(2) Time for making elections--(i) In general.
Except as otherwise provided in this section, the elections
specified in paragraph (a)(1) of this section shall be made
by the later of--
(A) The due date (taking extensions into account)
of the tax return for the first taxable year for which
the election is to be effective, or
(B) April 15, 1987 (in which case the election
generally must be made by amended return).
Section 5h.5(a)(3) provides,
(a)(3) Manner of making elections--(i) In general.
Except as otherwise provided in this section, the elections
specified in paragraph (a)(1) of this section shall be made
by attaching a statement to the tax return for the taxable
year for which the election is to be effective. If because
of paragraph (a)(2)(i)(B) of this section the election may
be filed after the due date of the tax return for the first
taxable year for which the election is to be effective, such
statement must be attached to a tax return or amended return
for the taxable year to which the election relates. Except
as otherwise provided in the return or in the instructions
accompanying the return for the taxable year, the statement
shall--
(A) Contain the name, address and taxpayer
identification number of the electing taxpayer,
(B) Identify the election,
(C) Indicate the section of the Code (or, if the
provision is not codified, the section of the Act)
under which the election is made,
(D) Specify, as applicable, the period for which
the election is being made and/or the property or other
items to which the election is to apply, and
(E) Provide any information required by the
relevant statutory provisions and any information
necessary to show that the taxpayer is entitled to make
the election.
A. Guaranteed
Guaranteed did not meet the requirements for the tax year
ending December 31, 1987. Guaranteed did attach a statement--
Statement 2--to its tax return for the taxable year ending
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