In PLR 201007062, the IRS ruled that a private foundation organized as a trust could have an additional five years to dispose of certain excess business holdings, namely radio stations. The IRS found that radio stations are hard to sell, due to a dramatic decline in the number of stations sales since 2007, and that the offering price for the radio stations would be substantially below market value. Furthermore, financing for the purchase of radio stations was not available to potential buyers. Based upon these impediments to sale, and the unique complexity of the setup of radio stations, the IRS granted the private foundation an additional five years for disposing of the radio stations.
See also PLR 201007066, where no potential buyers existed for the property at issue.
Posted by Jenny Robertson, Associate Editor, Wealth Strategies Journal.
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