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.