Request for Comments on Situations in Which a Section 6417(a) Election Could Be Made for Credits Purchased in Transfers Under Section 6418(a) (Notice 2024-27)

Please find attached comments by the American Public Power Association (APPA) on IRS Notice 2024-27, "Request for Comments on Situations in Which a Section 6417(a) Election Could Be Made for Credits Purchased in Transfers Under Section 6418(a)." In response to the specific questions asked by the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) in Notice 2024-27, APPA strongly believes that there is no situation in which an election under section 6417(a) could or should be made for a credit that was purchased in a transfer for which an election under section 6418(a) is made, commonly known as chaining.