ABC Rentals of San Antonio, Inc., et al - Page 18

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               shall be made by the due date (taking extensions into                  
               account) of the tax return for the first taxable year for              
               which the election is to be made.  The tax return must be              
               accompanied by a statement identifying the election by                 
               reference to Code or Act section and identifying the                   
               property items for which the election is being made.                   
               Section 5h.5, Temporary Tax Reform Act of 1986 Election                
          Regs., 52 Fed. Reg. 3624 (Feb. 5, 1987), effective February 5,              
          1987, applies to section 168(f)(1) elections and sets forth the             
          time and manner guidelines for elections made after October 22,             
          1986.  The election for section 168(f)(1) is available for                  
          property placed in service after December 31, 1986.  Section                
          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             






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