The IRS has granted extensions of time to several taxpayers who missed the deadline for requesting automatic IRS consent to change a method of accounting under the repair regs. The IRS gave the taxpayer an additional 60 days (after the IRS issued the favorable letter ruling) to make the election.
In one sample ruling request, the taxpayer (a corporation) was required to submit the original of Form 3115 with its timely income tax return filed for the year of change, and to provide a copy of the Form 3115 to the IRS in Ogden, Utah. The taxpayer’s return preparer timely e-filed the taxpayer’s Form 1120, prepared Form 3115, and submitted a copy of the form to Ogden. However, the preparer inadvertently failed to scan the Form 3115 and include it with the taxpayer’s return. The preparer discovered the omission and the taxpayer applied for an extension. The IRS granted the taxpayer an additional 60 days to elect the change of accounting method permitted under the repair regs.