How it works
From an IRS release to a cited sentence.
What happens between a document’s publication and a sentence in your answer, followed with one real ruling: IRS Private Letter Ruling 202627005.
01Published
The IRS releases a document.
A private letter ruling is published on irs.gov with its number and release date. The ruling answers one taxpayer’s request, so it is recorded as nonprecedential from the start, and that status stays with every passage taken from it.
- Publisher
- Internal Revenue Service
- Document
- IRS Private Letter Ruling 202627005
- Released
- July 2, 2026
- Address
- irs.gov/pub/irs-wd/202627005.pdf
- Status
- Private letter ruling · Nonprecedential
02Kept
The original is kept as published.
Virtus stores the publisher’s file unchanged and identifies it by its fingerprint. The text it searches is derived from that file and kept separately, so the document you open is always the one the IRS released.
202627005.pdf
Original file, stored as published
SHA-256 fingerprint
ba970100e1e0ab52beeb4f40d1940f17766e4f8f620b5ebe9e2a2d27b8838ed6
The original
Never edited. It is what you open and download.
The searchable text
Derived from it and kept separately.
03Read by page
The text is read page by page.
Each passage keeps the page it sits on; a Code section or regulation keeps its section. Text from a scanned page is identified as a transcription, and a page that cannot be read reliably is held back.
- Page 3
Section 1361(a)(1) provides that the term “S corporation” means, with respect to any taxable year, a small business corporation for which an election under § 1362(a) is in effect for the taxable year.
- Page 4
Sections 301.9100-1 through 301.9100-3 provide the standards the Commissioner will use to determine whether to grant an extension of time to make an election.
Based solely on the facts submitted and representations made, we conclude that X has satisfied the requirements of §§ 301.9100-1 and 301.9100-3 with respect to the QSub elections for Sub 1, Sub 2, Sub 3, Sub 4, Sub 5, and Sub 9.
04Found
Your question finds passages.
A question in plain words is searched against those passages. What comes back is a set of candidates with their pages. A matching word tells Virtus where to look; it is not yet evidence.
Did the IRS give more time for the missed QSub elections?
Passages retrieved for the question
- p. 4Based solely on the facts submitted and representations made, we conclude…
- p. 4Sections 301.9100-1 through 301.9100-3 provide the standards…
- p. 3Section 1361(a)(1) provides that the term “S corporation” means…
05Checked
Every sentence is checked.
The answer is written from the retrieved passages. Before it is shown, each sentence must carry a citation that resolves to a published passage, with its exact page or section and matching text. A sentence that fails is removed. If none survive, you see “No cited answer” instead.
Draft answer, sentence by sentence
The IRS concluded that the taxpayer met the requirements for more time under §§ 301.9100-1 and 301.9100-3 to make QSub elections it had missed for six subsidiaries. 1
Kept · [1] resolves to IRS Private Letter Ruling 202627005, page 4, and the quoted text matches
Relief of this kind is granted automatically for any late election, whatever the facts.
Removed · no published passage supports it
Go further