Washington Tax Alert July 31, 2006

The Service recently issued a private letter ruling permitting a taxpayer to revoke its election not to deduct additional bonus depreciation under IRC § 168(k). The taxpayer was allowed to file an amended tax return revoking its election not to claim bonus depreciation, and instead claim additional depreciation for property placed in service in a taxable year. See PLR 200626038. In issuing this ruling, the IRS National Office applied the same factors it would in a 9100 ruling application requesting permission to make a regulatory election that was missed.