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IRS release on expedited request for letter rulings (COVID-19)

IRS release on expedited request for letter rulings

The IRS today—in a release reminding taxpayers of the availability of expedited requests for letter rulings—noted that the coronavirus (COVID-19) pandemic is a “factor outside of the taxpayer’s control” and as such can support a request for expedited handling under Rev. Proc. 2020-1.

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The IRS release—IR-2020-212—explains that under Rev. Proc. 2020-1, the IRS ordinarily processes requests for letter rulings in the order that they are received, but that a taxpayer with a compelling need to have a request processed more quickly may request expedited handling.

  • A request for expedited handling must be made in writing, preferably in a separate letter submitted with the letter ruling request.
  • Requests for expedited handling are granted at the discretion of the IRS and typically involve a factor outside of the taxpayer's control that creates a real business need to obtain a letter ruling before a certain date in order to avoid serious business consequences.
  • Requests for expedited handling need to be submitted as promptly as possible after the taxpayer has become aware of the deadline or compelling business need.

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