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To make the election, the partnership must have had 100 or more partners during the preceding tax year.

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Service partners are those partners who perform substantial services in connection with the partnership's activities or who have performed such services in the past.

Service partnerships are not eligible to make the election if substantially all of the partners are: In addition, commodity partnerships are not eligible to make the election.

A limited liability company (LLC) is an entity formed under state law by filing articles of organization as an LLC.

Unlike a partnership, none of the members of an LLC is personally liable for its debts.

The ELP's tax year ends on the date of termination which is the date the ELP winds up its affairs.

Special rules apply in the case of a merger, consolidation, or division of a partnership. The IRS may waive the electronic filing rules if the partnership demonstrates that a hardship would result if it were required to file its return electronically.

The election applies to the tax year for which it was made and all later tax years.

This election cannot be revoked without IRS consent.

A partnership is the relationship between two or more persons who join to carry on a trade or business, with each person contributing money, property, labor, or skill and each expecting to share in the profits and losses of the business whether or not a formal partnership agreement is made.

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