IRS may extend Form 1099-R filing time but not change deadline
Number
202346012
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Information Relating to Certain Trusts and Annuity Plans; Certain Information Returns
Code sections
§ 6047, § 6071
Ruling dated
May 17, 2022
Publicly released
November 17, 2023
Source
Apply this to your situation
This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2023, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)
Plain-English summary
Chief Counsel advised that the IRS may grant extensions for filing Form 1099-R but cannot change the filing deadline itself under the current rules. A filer may obtain an initial 30-day extension without stating a reason. A second 30-day extension may be available when the filer provides a reason on Form 8809.
Ruling snapshot
- Question: May the IRS change the Form 1099-R filing deadline?
- Outcome: Advice given, extensions are allowed but the deadline itself cannot be changed
- Key authorities: IRC §§ 6047 and 6071; Form 8809 procedures
Full text (IRS public release)
ID: CCA_2022051713365550 [Third Party Communication:
UILC: 6071.02-00, 6047.00-00 Date of Communication: Month DD, YYYY]
Number: 202346012
Release Date: 11/17/2023
From: ---------------------
Sent: Tuesday, May 17, 2022 1:36:56 PM
To: ---------------
Cc: ----------------------
Bcc:
Subject: RE: Your help is appreciated - Form owner of the 1099-R for discussion related to possible
changes to the filing deadlines
That’s correct. Of course, the Service can grant an extension. Under the current rules,
for example, one could obtain a 30-day extension for filing the 1099-R without providing
a reason, and another 30 day extension with reason provided via Form 8809. But the
deadline itself could not be changed.
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