754 Election

[S&D Associates]

Help clear up something for me.

1. At what time is 754 election made?
2.Can it be made by a partner or does partnership have to make it?
3.When is request for automatic extension for 754 election made?

Please feel free to elaborate.

[Rapid Robert]

TheTaxBook (our host) has a few paragraphs on this. The partnership needs to make the election, and read the Author's Comment below for further consideration.

Making the election. The IRC section 754 election is made by
attaching a written statement to Form 1065 filed by the due date,
including extensions. The statement must include the name and
address of the partnership, be signed by one of the partners, and
state that the partnership elects under IRC section 754 to apply
IRC section 734(b) and IRC section 743(b). Once the election is
made, it cannot be revoked without IRS consent. If the election
cannot be made with the tax return, an extension of up to 12
months is available. See Treasury Regulation section 1.754-1(b)
for more information about making an IRC section 754 election.
[Reg. ?1.754-1(b)]

Request for IRC section 754 revocation. Taxpayers may request
revocation of a previous IRC section 754 election using Form
15254, Request for Section 754 Revocation.

Author’s Comment: Since the election is revocable only with IRS
consent and all future transactions must follow the rules of IRC sec-
tion 754, care should be taken when making the election as it may be
advantageous for the current situation, but it may not be desirable for
future transactions