A private letter ruling (PLR) is a written response issued by the IRS to an owner or taxpayer when the owner asks a question about the tax effects of its acts or transactions. The questions posed by site owners usually entail uncertainty about how to handle a situation and the need for guidance on how to avoid the recapture of tax credits. The IRS-issued PLR interprets and applies the law to a specific set of facts, and the owner or manager who requested the PLR can rely on the conclusions expressed in it.

Facts: The site owner of a single-building project requested an extension of time to make an election under Section 42(g)(1) of the Internal Revenue Code. Here, the owner inadvertently failed to make a timely, correct election for the building under Section 42(g)(1), consistent with the owner’s intent, as shown by submitted documentation. Section 42(g)(1) defines the term “qualified low-income housing project” as any project for residential rental property that meets the requirements of Section 42(g)(1)(A) or (B), whichever is elected by the taxpayer.

Facts: An owner requested a letter ruling on whether certain easement relocation costs incurred while constructing a site are includible in the eligible basis for purposes of Section 42(d)(1) of the Internal Revenue Code.