Extra time granted to file late Forms 3115 for an inventory accounting-method change
Plain-English summary
A corporation that heads a consolidated group hired a CPA to change how it and
its subsidiaries identify and allocate costs to inventory under Section 263A.
That change requires filing Form 3115 (Application for Change in Accounting
Method) using the automatic-consent procedures of Rev. Proc. 2015-13, and the
form has to be filed twice: the original attached to the timely filed return
and a duplicate copy mailed separately to the IRS. The CPA mailed the two
duplicate copies on time, but by inadvertence never attached the two original
Forms 3115 to the electronically filed return. After discovering the slip, the
taxpayer asked for an extension of time under Treasury Regulations 301.9100-1
and 301.9100-3. The IRS concluded the taxpayer acted reasonably and in good
faith, so it granted 45 days from the date of the letter to file the original
forms. This matters because automatic accounting-method changes have a two-part
filing step, and missing the attach-to-return part can often be fixed through
9100 relief.
Ruling snapshot
- Question: Should the taxpayer get more time under § 301.9100-3 to file the two original Forms 3115 for its inventory accounting-method change?
- Outcome: Approved (45 days from the date of the letter)
- Key authorities: IRC §§ 446(e), 263A; Treas. Reg. §§ 301.9100-1 through 301.9100-3; Rev. Proc. 2015-13
Full text (IRS public release)
Internal Revenue Service Department of the Treasury
Washington, DC 20224
Number: 202618007 Third Party Communication: None
Release Date: 5/1/2026 Date of Communication: Not Applicable
Index Number: 9100.10-00
Person To Contact:
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------------------- Telephone Number:
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---------------------------- Refer Reply To:
CC:ITA:B06
------------------------------ PLR-115069-25
----------------------------------------------------------- Date:
February 02, 2026
LEGEND:
CPA = ----------------------
Taxpayer = -----------------
Subsidiaries = -----------------------------------------------------------------------------
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Year = -----------------------------------------------------------------------------
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Date A = -------------------
Date B = ------------------
Month = -------------
Dear ----------------:
This ruling responds to a recent letter submitted by CPA, Taxpayer's authorized
representative, on behalf of Taxpayer and its Subsidiaries. CPA has requested 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 two original Forms 3115, Application for Change in Accounting
Method for Year.
FACTS
Taxpayer represents the following facts:
Taxpayer is a corporation and the parent of an affiliated group of corporations that files
a U.S. federal consolidated income tax return.
Taxpayer engaged CPA to prepare and file a consolidated federal income tax return for
Year and to prepare and file two Forms 3115, Application for Change in Accounting
Method, for Year to change the methods of accounting used by Taxpayer and its
Subsidiaries for identifying and allocating costs to inventory under § 263A using the
automatic consent procedures under Rev. Proc. 2015-13 and Rev. Proc. 2024-23,
2023-28 I.R.B. 1207. CPA prepared both Forms 3115 using the automatic consent
procedures of Rev. Proc. 2015-13 and Rev. Proc. 2023-24, 2023-28 I.R.B. 1207.
In completing its duties, CPA mailed the duplicate copy of both Forms 3115 to the
appropriate location in Ogden, UT on Date A. CPA timely and electronically filed
Taxpayer's consolidated federal income tax return by its due date, Date B. See section
6.03(1)(a)(i) of Rev. Proc. 2015-13. The return was filed on a basis consistent with
Taxpayer's method changes, and those of Subsidiaries, having been properly
implemented. However, in Month, Taxpayer discovered that, through inadvertence,
CPA had failed to upload both original Forms 3115 to Taxpayer's timely electronically
filed federal income tax return. See section 6.03(1)(a)(i)(A) of Rev. Proc. 2015-13.
CPA subsequently submitted this request for an extension of time to file Taxpayer's and
Subsidiaries' original Forms 3115.
RULING REQUESTED
Taxpayer requests an extension of time pursuant to §§ 301.9100-1 and 301.9100-3 to
file both original Forms 3115 required by Rev. Proc. 2015-13 to change its methods of
accounting, and those of Subsidiaries, for identifying and allocating costs to inventory
under §§ 263A and 446(e).
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.
Section 301.9100-1(c) provides that the Commissioner has discretion to grant a
reasonable extension of time under rules set forth 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 the
original Forms 3115 (identical to the duplicate copies already filed with the Internal
Revenue Service) changing Taxpayer's methods of accounting, and those of
Subsidiaries, for identifying and allocating costs to inventory for Year. Please attach a
copy of this letter ruling to the amended return.
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
attempted to make on behalf of itself and Subsidiaries are eligible to be made under the
automatic consent procedures of Rev. Proc. 2015-13 and Rev. Proc. 2023-24, or
whether Taxpayer and Subsidiaries otherwise meet the requirements of Rev. Proc.
2015-13 to make accounting method changes using Rev. Proc. 2015-13. We express
no opinion regarding either Taxpayer's accounting methods or Subsidiaries' accounting
methods for any specific items under the proposed methods.
The ruling contained in this letter ruling is based upon facts and representations
submitted by CPA on behalf of itself and 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 Form 3115, all material is subject to verification on examination.
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,
ELIZABETH A. BOONE
Assistant to the Branch Chief, Branch 6
Office of Associate Chief Counsel
(Income Tax & Accounting)
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