Posts Tagged Post Modernism
Dear IRS Man, I Made a Mistake (And So Did My Accountant)
DEAR IRS MAN, I MADE A MISTAKE (AND SO DID MY ACCOUNTANT)
(A) In general.
A business entity that is not classified as a corporation
under section 301.7701-2(b)(1), (3), (4), (5), (6), (7), or (8) (an eligible entity)
can elect its classification
for federal tax purposes [No Shit]
as provided in this section.
An eligible entity with at least two members can elect to be classified
as either an association
(and thus a corporation under section 301.7701-2(b)(2))
or a partnership,
and an eligible entity with a single owner can elect to be classified
as an association
or to be DISREGARDED [really?]
as an entity separate from its owner.
Paragraph (b) of this section provides a default
classification for an eligible entity
that does not make an election.
Thus, elections are necessary only when an eligible
entity chooses to classified initially as other than the default
classification or when an eligible entity
chooses to change
its classification. An entity
whose classification is determined
under the default
classification retains that classification
(regardless of any changes in the members’
at any time
during the time
that the entity’s
classification is relevant as defined in paragraph (d)
of this section) [end of parenthetical, remember line 24?]
until the entity makes an election to change that classification
under paragraph (c )(1)
of this section.
Paragraph (c ) of this section provides rules
[Haven’t we had enough F’in rules by now?]
for making express elections. Paragraph (d)
of this section provides special rules for foreign eligible entities
[The IRS nails nails you no matter where you are in the world!].
Paragraph (e ) of this section
special rules [special stinky sauce]
for classifying entities resulting from partnership terminations
under section 708(b). Paragraph (f) of this section
sets forth [in stone]
the effective date of this section [which section were we in?]
special rule [what do you know?]
relating to prior periods. . . .