Rev. Rul. 55-465

Treasury Decision 6124, C.B. 1955-1, 719, provides that statements of election under the provisions of section 1361 of the Internal Revenue Code of 1954, whereby certain unincorporated business enterprises may elect to be taxed as domestic corporations, must contain certain specified information and commitments. However, with respect to the calendar year 1954, Treasury Decision 6124 was promulgated at such a late date (February 24, 1955) that there was apparently insufficient time for meeting its requirements within the 60 day period which section 1361(a) of the Code allows for the making of an election after the close of any taxable year. Accordingly, where taxpayers, for the calendar year 1954, have filed a timely statement of election under section 1361 of the Code which statement does not wholly conform to the requirements set forth in Treasury Decision 6124, such taxpayers will be afforded an opportunity to bring such statement into conformity with such requirements within a reasonable period of time, in no event to be later than the time allowed by paragraph 23(b)(3), as added to T.D. 6118, C.B. 1955-1, 698, by T.D. 6124, supra , for the perfecting of the election by the filing of a return or amended return, as the case may be, on Form 1120