The IRS today updated a list of “frequently asked questions” (FAQs) concerning the postponed deadlines for filing federal income tax returns and paying federal taxes in response to the coronavirus (COVID-19) pandemic.
The FAQs—originally posted on March 24, 2020, shortly after the IRS issued in Notice 2020-18—were subsequently updated to reflect guidance included in Notice 2020-20 and Notice 2020-23 that amplified the guidance from Notice 2020-18. Read TaxNewsFlash that includes text of the FAQs (as of April 23, 2020).
Today’s update to the FAQs (updated April 28, 2020) includes this new information (note that the FAQs are not numbered in today’s update):
Q. How does this notice operate with the Tax Court case of Guralnik v. Commissioner, 146 T.C. 230 (2016), which applied Federal Rule of Civil Procedure 6(a)(3)(A) to provide additional time for the filing of a petition when the clerk’s office was closed due to a snow emergency? Does the taxpayer get the benefit of both periods? (added April 27, 2020)
A. Yes, a taxpayer will get the benefit of both periods. For example, if the last day for filing a petition fell on March 19, 2020, the date that the Tax Court closed, the taxpayer will get the benefit of Guralnik from March 19, 2020 and the benefit of this notice from April 1, 2020 until July 15, 2020. If the court were to reopen before the expiration of the notice postponement period, the taxpayer will get the benefit of the postponement until July 15, 2020. If the court reopens after the notice postponement period (that is, after July 15, 2020), the due date for the taxpayer’s petition is extended to the Tax Court’s reopening date under Guralnik and the relief under Notice 2020-23 does not apply.
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