Redemption – PLR 201228012
a. Briefly (1 or 2 sentences for each issue) describe the issues. There were 7 rulings given -restate as questions
b. Describe the central facts and representations
c. How does §302 apply? Describe all provisions of §302(b) and whether they are relevant in the PLR
d. Why did the S Election remain valid?
e. Did §318 attribution apply? Why and if yes, how was it addressed
? Provide appropriate citations and references