Allowable distribution period - Taxes on failure to distribute income

The allowable distribution period begins on the first day of the first tax year following the tax year in which an incorrect valuation of foundation assets occurred.  The period ends 90 days after a notice of deficiency for the initial tax is mailed.  This period is extended by any period in which the deficiency cannot be assessed, and any other period which the IRS determines is reasonable and necessary to permit a distribution of undistributed income as required under section 4942.  Where a notice of deficiency is not mailed because there is a waiver of restrictions on assessment and collection of a deficiency or because the deficiency is paid, the filing date of the waiver or the date of payment, is treated as the end of the allowable distribution period.

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