April 13, 2020

IRS Suspends Processing for Paper Filed Returns, Postpones More Deadlines


This article was updated on April 14,

The IRS announced on April 9 that it suspended processing all paper filed individual tax returns until further notice, and that its ability to process all other paper filed returns is “extremely limited.” This news comes shortly after reports surfaced that the IRS temporarily shuttered several offices at its national processing campus in Ogden, UT on April 8 as a result of a stay-at-home order resulting from the state’s response to the COVID-19 pandemic. The IRS also announced on April 9 that it postponed to July 15, 2020 the due date for the remainder of practically all other federal tax forms and “time sensitive actions” that it had not previously postponed. Delays in the processing of paper filed returns might also delay refunds related to recent tax changes enacted by the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

Paper Filed Return Processing Halted

The IRS provided in its announcement, “The IRS is not currently able to process individual paper tax returns,” and added, “Paper returns will be processed once processing centers are able to reopen.” Certain taxpayers who may be exempt from filing a return were prompted to file in order to establish eligibility for an advance Recovery Rebate payment. Fortunately, the IRS established an online portal on April 10 that allows these taxpayers to submit basic information so that their advance Recovery Rebate payment can be processed without the need to file a return.

The IRS operating status initially placed into question the ability for businesses and individuals to obtain refunds quickly from net operating loss (NOL) carryback claims. Individuals file net operating loss carryback claims on Form 1045, and corporations file carryback claims on Form 1139. But, the only way that either of these forms can be filed is by paper. Because IRS processing for paper tax returns is now “extremely limited,” there is not adequate IRS personnel to sort the mail that they receive or process it. Fortunately, the IRS pivoted quickly with an innovative solution to this unique problem, and announced on April 13 that Forms 1139 and 1045 can be faxed until further notice. This is a great solution for filers of Forms 1139 and 1045, but other filers seeking refund claims with traditional amended tax returns must plan for the contingency that their paper-filed amended tax returns will not be processed until IRS campuses re-open.

IRS Postpones More Deadlines

Previously, the IRS postponed to July 15 the due date for any taxpayer with an income tax return or income tax payment due on April 15. The IRS later supplemented this tax relief with a due date postponement to July 15 for federal gift tax return and associated excise tax payments. While very helpful, the previous measures excluded relief for nonprofits, second quarter estimated tax deposits, and left considerable uncertainty about the due date of various form attachments (such as Form 3520, Form 5471, and Form 5472).

The IRS swept up all of these lingering concerns with its April 9 announcement that the due date for the remainder of practically all other federal tax forms and federal tax payment obligations, as well as other “time sensitive actions” is postponed to July 15. The April 9 announcement does not postpone the time to file payroll tax returns and make payroll tax deposits; employers must continue to file Form 941 and make corresponding payments under the normal due date procedures. A complete list of “time sensitive actions” postponed until July 15 can be found in Rev. Proc. 2018-58.

To be eligible for the new relief, the due date must fall on or after April 1, 2020 and before July 15, 2020. Further, the IRS postponed the due date for second quarter estimated tax deposits for individuals, corporations, trusts and nonprofits to July 15. This means that both the first and the second quarter tax deposit obligations for these taxpayers are now due July 15. The relief also applies to installment payments under Section 965(h) due on or after April 1, 2020 and before July 15, 2020.

As a result of the April 9 IRS announcement, the due date for all time sensitive actions listed under Rev. Proc. 2018-58 is postponed to July 15. Following is a list of the common tax forms and time sensitive actions that are now covered under the IRS filing and payment relief:

Primary tax returns
Form 1040 Form 1120 Form 1120S
Form 1065 Form 1041 Form 706
Form 709 Form 4720 Form 5227
Form 990 Form 990-PF Form 990-T
Estimated tax deposits
Form 1040-ES Form 1120-W Form 1041-ES
Form 990-W    
Schedules and other form attachments
Form 1040, Schedule H Form 1040, Schedule SE Form 3520
Form 5471 Form 5472 Form 8621
Form 8858 Form 8865 Form 8938
Form 1128 Form 3115 Form 8716
Form 8752 Form 8832 Form 4466
Form 5500 Form 8804 Form 8805
Form 2553 Form 8308 Form 1139
Form 1045    
Other Time-Sensitive Actions
Elections to be made on a specified form or attachment (including under Section 83(b))
Section 1031 like-kind exchange identification period and exchange period
Section 1042 replacement period for sale of stock to an ESOP


Final Thoughts


Individuals and businesses are eagerly awaiting refunds from planned net operating loss carryback claims, and the new fax procedures allow them quick access to cash funds. Others that must file traditional amended tax returns must consider the possibility that the IRS may be unable to process these paper-filed claims in the near term. Fortunately, the lingering concerns about the scope of the July 15 tax filing and payment relief were assuaged with the April 9 IRS guidance. We will keep you apprised of further developments in this area. Should you have any questions, please contact your local CBIZ tax advisor.

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