The IRS this week released guidance for employees of the Tax Exempt and Government Entities (TE/GE) Division regarding the extended “information document request” (IDR) timelines due to the coronavirus (COVID-19) pandemic.
The memorandum—TE/GE-04-1220-0031 [PDF 126 KB]—supersedes an earlier memo (July 2020) and:
The current memo (December 2020) was issued by the Commissioner of the TE/GE Division of the IRS, and supersedes a July 2020 memo that had in turn previously superseded an April 2020 memorandum that had provided IDR enforcement timelines in response to the COVID-19 situation. Today’s memo (as did the prior versions) includes this rationale for the relief:
This modification temporarily relaxes the more rigid timelines detailed within the above IRM sections that would otherwise result in enforcement actions due to untimely or incomplete IDR responses. We are issuing this modification to strict adherence of the timelines present within our IRMs in recognition of the difficulty taxpayers may face at this time due to the various challenges associated with COVID-19. The intent of this modification is to allow an increased reasonable application of business judgement by examiners and managers in the exercise of duties related to IDR requests and follow-ups. These modified IDR procedures will be effective until further notice.
The memorandum also provides that “all operations” will continue normal procedures, except that:
For more information, contact a tax professional with KPMG’s Washington National Tax practice:
Ruth Madrigal | +1 202 533 8817 | ruthmadrigal@kpmg.com
Preston Quesenberry | +1 202 533 3985 | pquesenberry@kpmg.com
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.