COVID relief does not extend offer deadline outside relief window

Plain-English summary

Chief Counsel considered whether COVID-19 deadline relief extended a 24-month period for the IRS to accept an offer in compromise described in the email as an OIC-DALT. Notice 2020-23, its predecessors, and Section 7508A did not extend that period when its original deadline fell outside the specified relief window. The relevant window ran from April 6 through July 15, 2020. Therefore, a deadline outside that range remained unchanged.

Ruling snapshot

• Question: Did the COVID-19 notices extend the IRS's 24-month offer-acceptance period when the original deadline fell outside the relief window?
• Outcome: Advice given: no.
• Key authorities: IRC § 7508A; Notice 2020-23 and its predecessor COVID-19 notices

Full text (IRS public release)

ID: CCA_2020041716200148
UILC: 7508A.00-00

Number: 202129008
Release Date: 7/23/2021
From: ----------------------
Sent: Friday, April 17, 2020 4:20:01 PM
To: ---------------------
Cc: ----------------------------------------------------------------------------------
Bcc:
Subject: RE: Notice 2020-23, extension for Government Acts

Hi ------:

You and Walt correctly concluded that nothing in the current COVID notices (including
2020-23 and its predecessors), nor in 7508A itself, would extend the 24-month period
for the IRS to accept an OIC-DALT if the original deadline doesn’t fall between April 6,
2020 and July 15, 2020.

Please let me know if you have any questions or would like to discuss.

Thanks,
-------

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