Combat-zone disregarded days use the taxpayer's entry date

Plain-English summary

Chief Counsel advised how to compute the section 7508 period that is disregarded for tax deadlines when a taxpayer serves in a combat zone. The relevant date for measuring the filing-season days remaining is the date the taxpayer entered the combat zone. Those remaining filing-season days are included in the disregarded period because the cited revenue ruling measures them when combat-zone service began. The email gave no further factual or computational detail.

Ruling snapshot

• Question: Which date determines the remaining filing-season days included in the section 7508 disregarded period?
• Outcome: advice given, use the combat-zone entry date
• Key authorities: IRC § 7508; the revenue ruling quoted in the advice

Full text (IRS public release)

ID:       CCA_2017102313372053
UILC:     7508.00-00

Number: 201748009
Release Date: 12/1/2017
From:
Sent: Monday, October 23, 2017 1:37:20 PM
To:
Cc:
Bcc:
Subject: RE: Technical Application of IRC 7508 with respect to the computation of interest and other
additions to tax based on the return due date


Hello ---------

----------- is correct. The date that matters for determining how many remaining filing
season days are included in the disregarded count is the entry date. The Rev. Rul.
states that the disregarded days include the filing season days remaining “at the time
the taxpayer began serving in the combat zone.”

If you still have a concern about this, please discuss it with your manager.

Thanks.
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