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05-27-2020
11:31 AM
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No argument that it is a short period. However, it is for a short period related to the elected period of 10/1/2015 through 9/30/2016.
If the taxpayer files another 2016 tax return, the total months for filing a 2016 return will exceed the 12 month rule of the noted regulation.
It is doubtful that we will agree, but I am satisfied with my opinion that the original return was filed on a wrong year tax return. Anything else, and 2016 will have more than 12 months of reporting.