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IRS Extends More Key Deadlines in Response to COVID-19

Client Updates

On April 9, 2020, the Internal Revenue Service (“IRS”) issued Notice 2020-23, which extends key deadlines for nearly all taxpayers that have a filing or payment obligation falling on or after April 1, 2020, and before July 15, 2020. The full press release is available at IRS News Release IR-2020-66.

Notice 2020-23 expands on prior relief announced last month in Notices 2020-18 and 2020-20, in which the IRS extended the deadline for filings and payments of federal income taxes and federal gift (and generation skipping transfer) taxes to July 15, 2020. The IRS had also recently announced the People First Initiative (discussed by us here), which provides deadline extensions and other relief to taxpayers under audit or subject to enforced collection actions.

Noteworthy provisions in Notice 2020-23 include the following:

  • July 15, 2020 Extension for Tax Filings and Payments. Taxpayers have until July 15, 2020 to meet filing and payment obligations for a wide variety of taxes. This extension specifically applies with respect to “all schedules” and “other forms that are filed as attachments” to the tax returns, including for example Schedule H and Schedule SE and Forms 3520, 5471, 5472, 8621, 8858, 8865, and 8938.
  • July 15, 2020 Extension for Petitions, Claims, and Suits. Taxpayers have until July 15, 2020 to perform all “Specified Time-Sensitive Actions,” which include:
    i. filing all petitions with the Tax Court,
    ii. filing a claim for credit or refund of any tax, and
    iii. bringing suit upon a claim for credit or refund of any tax.
    Notice 2020-23 does not provide relief for the time period for filing a petition with the Tax Court, or for filing a claim or bringing a suit for credit or refund, if that period expired before April 1, 2020.
  • 30-Day Extension for IRS Employees. IRS employees have an additional 30 days to perform all “Time-Sensitive IRS Actions,” including:
    i. assessing any tax,
    ii. giving or making any notice or demand for the payment of any tax,
    iii. collecting the amount of any liability in respect of any tax,
    iv. bringing suit in respect of any liability in respect of tax, and
    v. allowing a credit or refund of any tax.
    This 30-day extension applies to certain taxpayers when these deadlines fall on or after April 6, 2020 and before July 15, 2020.

The relief under Notice 2020-23 is automatic. Taxpayers do not need to call the IRS or file any extension forms, or send letters or other documents to receive this relief. Also, it does not appear that an IRS employee must notify the taxpayer if the IRS employee takes advantage of the 30-day extension on certain actions offered under Notice 2020-23.

Should you have any questions or concerns about Notice 2020-23, please contact any of the authors of this update.

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