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Requests for Letter Rulings Expedited by IRS

The Internal Revenue Service says it’s continuing to look for ways to assist taxpayers taxpayers who’ve been affected by the COVID-19 pandemic. To that end, the agency is reminding taxpayers and tax professionals alike there are special procedures in place to speed up requests for letter rulings under Rev. Proc. 2020-1, 2020-1 I.R.B. 1 (January 2, 2020).

As Rev. Proc. 2020-1 sets out, the IRS ordinarily processes requests for letter rulings in the order they’re received. A taxpayer who has a compelling need to have a request processed more quickly can request expedited handling.

A request for expedited handling must be made in writing -- preferably in a separate letter submitted with the letter ruling request. Applications for expedited handling are granted at the discretion of the IRS and typically involve factors outside the taxpayer’s control that create a real need to obtain a letter ruling before a certain date to avoid serious business consequences.

Expedited-handling requests should be submitted as promptly as possible after the taxpayer becomes aware of the deadline or compelling need.

Does the coronavirus qualify as a factor outside a taxpayer's control?

The COVID-19 pandemic is one of the factors outside a taxpayer’s control that can support a request for expedited handling under Rev. Proc. 2020-1.

As a result, taxpayers are encouraged to seek expedited handling if they face a compelling need related to COVID-19. This is consistent with Executive Order 13924 of May 9, 2020.

Information on procedures for requesting expedited handling is provided in Section 7.02(4) of Rev. Proc. 2020-1.

Rev. Proc. 2020-29, 2020-21 I.R.B. 859 (May 18, 2020), also sets out procedures for electronic submission of letter-ruling requests.

Bob Williams

Forget genes; I’ve got words in my DNA. Communication has been part of who I am nearly all my life. From a long career in radio news to another one in newspapers – and a University of Georgia journalism degree sandwiched between the two – language has been my life. I’ve also been fortunate to have learned the tax business from the ground up here at Drake, starting with 1040.com online forms some years ago before moving on to work on the Web. In all things tax-ish, we aim to give you tools you can use.

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