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Section 6103(l)(21) does not permit the Treasury Department or the IRS to establish penalties under these regulations

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https://www.irs.gov/node/49746

This revenue procedure provides the exclusive simplified methods for taxpayers to request relief for late S corporation elections, ESBT elections, QSST elections, QSub elections, and late corporate classification elections which the taxpayer intended to take effect on the same date that the taxpayer intended that an S

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https://www.irs.gov/publications/p519

519, such as legislation enacted after it was published, go to IRS

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https://www.irs.gov/irb/2025-01_IRB

2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Rulings and Agreements, and the procedures that apply to requests for determination letters and private letter rulings

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https://www.irs.gov/publications/p17

However, the information given does not cover every situation and is not intended to replace the law or change its meaning

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https://www.irs.gov/instructions/iw7

If an ITIN is applied for on or before the due date of a return (including extensions) and the IRS issues an ITIN as a result of the application, the IRS will consider the ITIN as issued on or before the due date of the return