Partnership received 45 days to file signed duplicate Forms 3115

Plain-English summary

A partnership timely filed its return with two original Forms 3115 for automatic changes to its inventory capitalization and valuation methods. Its accountant also faxed duplicate copies to the IRS by the deadline, but the taxpayer had not signed them, so the duplicate-filing requirement was not satisfied. The IRS found that the partnership met the standards for regulatory-election relief and granted 45 days to file signed duplicate forms identical to the originals. The ruling did not decide whether the changes qualified for automatic consent or whether the proposed methods were proper.

Ruling snapshot

• Question: Could a partnership receive more time to file signed duplicate Forms 3115 after timely filing unsigned duplicates?
• Outcome: Relief approved, with 45 days to file the duplicates
• Key authorities: IRC §§ 263A, 446(e), 471; Rev. Proc. 2015-13; Treas. Reg. §§ 301.9100-1, 301.9100-3

Full text (IRS public release)

Internal Revenue Service Department of the Treasury
Washington, DC 20224

Number: 202538010 Third Party Communication: None
Release Date: 9/19/2025 Date of Communication: Not Applicable
Index Number: 9100.10-01, 9100.00-00
Person To Contact:
-------------------- ------------------, ID No. ------------
------------------------------ Telephone Number:

Refer Reply To:
CC:ITA:B6
PLR-107174-25
Date:
June 17, 2025

Legend

Taxpayer = -----------------------------------------------------------------------

CPA = ------------------------

Date A = ---------------------------

Year of Change = ---------------------------------------------------

Return = ----------------------------------------------------------------------

Dear ---------------:

This ruling responds to a letter that was submitted by Taxpayer’s representative, CPA.
CPA has asked that the Commissioner of the Internal Revenue Service give Taxpayer
an extension of time pursuant to §§ 301.9100-1 and 301.9100-3 of the Procedure and
Administration Regulations to file the duplicate copy of two Forms 3115, Application for
Change in Accounting Method.

FACTS

CPA and Taxpayer represent the following facts:

Taxpayer is a partnership for federal income tax purposes. Taxpayer files a federal
income tax return on a calendar-year basis.

Taxpayer engaged CPA to prepare its Return for the Year of Change and to include two
Forms 3115 with the Return for two automatic method changes for the Year of Change.
In the first Form 3115, Taxpayer was requesting permission to change its method of

PLR-107174-25 2

accounting for capitalizing inventory under § 263A. In the second Form 3115, Taxpayer
was requesting permission to change its method of accounting for valuing inventory
under § 471.

CPA timely electronically filed Taxpayer’s Return and the original Forms 3115 on Date
A, attaching the original Forms 3115 to the Return. Date A was the final day Taxpayer
could timely file its Return and the Forms 3115 for the Year of Change. One day prior
to Date A, CPA provided Taxpayer copies of the Forms 3115 and instructed Taxpayer
to sign and appropriately file these copies no later than Date A. On Date A, duplicate
copies of the Forms 3115 were transmitted via fax to the Service, but these copies were
not signed by Taxpayer.

Taxpayer did not successfully file the Forms 3115 because Taxpayer did not sign the
duplicate copies that were faxed to the Service. See section 6.03(1)(a)(i)(B) of Rev.
Proc. 2015-13, 2015-5 I.R.B. 419. CPA later submitted this request for an extension of
time for Taxpayer to appropriately file the duplicate copies of the Forms 3115.

RULING REQUESTED

Taxpayer requests an extension of time pursuant to §§ 301.9100-1 and 301.9100-3 to
file the duplicate copies of the Forms 3115 required by Rev. Proc. 2015-13 in order to:

1. Change Taxpayer’s method of accounting for capitalizing inventory under
   § 263A; and

2. Change Taxpayer’s method of accounting for valuing inventory under § 471.

LAW AND ANALYSIS

Rev. Proc. 2015-13 provides the procedures by which a taxpayer may obtain automatic
consent to change certain accounting methods. A taxpayer complying with all the
applicable provisions of this revenue procedure has obtained the consent of the
Commissioner to change its method of accounting under § 446(e) and the Income Tax
Regulations thereunder.

Section 6.03(1)(a)(i) of Rev. Proc. 2015-13 provides that a taxpayer changing an
accounting method pursuant to Rev. Proc. 2015-13 must complete and file a Form 3115
in duplicate. The original must be attached to the taxpayer’s timely filed (including any
extensions) original federal income tax return for the year of change, and a copy (with
signature) of the Form 3115 must be filed with the appropriate office of the Internal
Revenue Service no earlier than the first day of the year of change and no later than
when the original is filed with the federal income tax return for the year of change.

PLR-107174-25 3

Section 301.9100-1(c) provides that the Commissioner has discretion to grant a
reasonable extension of time under rules in §§ 301.9100-2 and 301.9100-3 to make
certain regulatory elections.

Sections 301.9100-1 through 301.9100-3 provide the standard the Commissioner will
use to determine whether to grant an extension of time to make an election.
Section 301.9100-2 provides automatic extensions of time for making certain elections.
Section 301.9100-3 provides extensions of time for making elections that do not meet
the requirements of § 301.9100-2.

Section 301.9100-3(a) provides that requests for relief subject to § 301.9100-3 will be
granted when the taxpayer provides evidence to establish to the satisfaction of the
Commissioner that the taxpayer acted reasonably and in good faith and that the
granting of relief will not prejudice the interests of the Government.

CONCLUSION

Based solely on the representations submitted, this office concludes that the
requirements of §§ 301.9100-1 and 301.9100-3 have been satisfied in this case.
Accordingly, Taxpayer is granted 45 calendar days from the date of this letter to file with
the appropriate Service location the required duplicate copies of the Forms 3115
(identical to the original copies already filed with the Service) changing:

1. Taxpayer’s method of accounting for capitalizing inventory under § 263A; and

2. Taxpayer’s method of accounting for valuing inventory under § 471.

Please attach a copy of this letter ruling to each duplicate copy.

Except as expressly set forth above, this office neither expresses nor implies any
opinion concerning the tax consequences of the facts described above under any other
provision of the Code or regulations. Specifically, we have no opinion, either expressed
or implied, concerning whether the accounting method changes Taxpayer has tried to
make are eligible to be made under the automatic consent procedures of Rev. Proc.
2015-13 or whether Taxpayer otherwise meets the requirements of Rev. Proc. 2015-13
to make accounting method changes using Rev. Proc. 2015-13. Further, we express no
opinion regarding the propriety of either of Taxpayer’s proposed methods of accounting.

The ruling contained in this letter ruling is based upon facts and representations
submitted by CPA or Taxpayer, with accompanying penalties of perjury statements
executed by appropriate parties. While this office has not verified any of the material
submitted in support of this request for an extension of time to file the required Forms
3115, all material is subject to verification on examination.

PLR-107174-25 4

This ruling is directed only to Taxpayer. Section 6110(k)(3) provides that it may not be
used or cited as precedent.

In accordance with the power of attorney on file with our office, we will send a copy of
this letter to each of Taxpayer’s authorized representatives.

Sincerely,

Brinton T. Warren
Special Counsel
Office of Associate Chief Counsel
(Income Tax & Accounting)

cc: ----------------------

ATTN: --------------------

ATTN: ---------------