Energy Company- Application of Section 475(e) – IRS Private Letter Ruling 201132021

Energy Company- Application of Section 475(e)

This Chief Counsel Advice responds to your request for assistance as to whether the Taxpayer properly applied mark-to-market treatment under section 475(e) to certain portions of a certain contractual Agreement. We are generally in agreement with your conclusions and analysis in the incoming request, and as such, we are only focusing our analysis on areas where we have some differences or those areas which may require further development. This advice may not be used or cited as precedent.