Additional Tax Deadlines Extended, Including Deadlines for the IRS

April 10, 2020 by

On April 9, 2020 the IRS issued Notice 2020-23, which amplifies three previous notices providing relief to IRS deadlines due to the COVID-19 pandemic. One unique aspect of the IRS Notice is that it also postpones due dates for certain government acts—thereby allowing the IRS additional time as well.

What additional deadlines are extended?

The new IRS Notice indicates that any person (i.e. individual, trust, estate, partnership, association, company or corporation) with a federal tax payment obligation or federal tax return or other form filing obligation due on or after April 1, 2020, and before July 15, 2020, is now extended until July 15th. The specific payments and forms are listed in the IRS Notice, but it covers most of what was left out previously.

Also, we previously indicated that Section 1031 exchanges were not extended here. The IRS Notice also incorporates time-sensitive actions covered by Revenue Procedure 2018-58, which covers Section 1031 exchanges and many other time-sensitive actions. Also, the IRS Notice specifically indicates that the Opportunity Zone deadlines under Section 1400Z-2(a)(1)(A) are also extended.

The IRS Notice also extends relief to filing petitions with the Tax Court, for review of a decision rendered by the Tax Court, and for filing a claim or bringing suit for credit or refund that falls after April 1, 2020 and before July 15, 2020. Therefore, the call to mind Tax Court petition deadlines in our previous article is now extended if your deadline expired after April 1, 2020. In short, virtually everything is now extended if the deadline to pay or file would have been after April 1, 2020 and on or before July 15, 2020.

What do you need to do to get the extension?

Nothing. According to the IRS Notice the relief is automatic and taxpayers do not need to call the IRS or file any extension forms. Given that the IRS recently closed its last open IRS Service Center there is very few IRS people left to process anything anyway.

What government deadlines are extended?

The IRS Notice also provides the IRS with additional time. Because the IRS may be unable to access documents, systems, or other resources because of increasing remote work requirements they are also being given relief. The Notice indicates that taxpayers currently under examination, having cases pending at IRS Appeals, or who submit amended returns or payments affecting assessment will have the IRS deadlines to act extended by 30 days. If the last day for the IRS to act falls on or after April 6, 2020 and before July 15, 2020 then taxpayers can add 30 days to the usual deadline. The IRS also leaves open the need for further postponement, if appropriate.

If you have questions about specific deadlines related to your own tax situation please contact me at or (214) 396-5962.

Joshua D. Smeltzer

Joshua D. Smeltzer is a tax attorney with over fifteen years of experience representing individuals, corporations, and formerly the U.S. Government in a variety of tax matters. Mr. Smeltzer uses the knowledge gained inside the government to represent and advise clients on potential tax risks, navigating the IRS labyrinth during audit examinations, arguing at the IRS Office of Appeals, and litigation in the federal courts. He also advises individual and corporate clients on a variety of tax compliance issues in an effort to avoid tax disputes from occurring.

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