45-day extension to file a late original Form 3115 for an accounting method change

Plain-English summary

A limited liability company taxed as a partnership asked the IRS for extra time
to fix a filing slip-up, and the IRS said yes. The company had been wrongly
treating leased vehicles as if it owned them, so it filed a Form 3115 (the form
used to change an accounting method) under the automatic-consent rules of Rev.
Proc. 2015-13 to switch to the correct treatment. Its accounting firm timely sent
the required duplicate copy of the Form 3115 to the IRS and timely filed the
partnership return, but inadvertently forgot to attach the original Form 3115 to
that return, which the rules require. Under Treas. Reg. §§ 301.9100-1 and
301.9100-3, the IRS can grant a reasonable extension to make a late regulatory
election when the taxpayer acted reasonably and in good faith and relief will not
prejudice the government. Finding those conditions met, the IRS gave the company
45 days from the date of the letter to file the original Form 3115. The IRS
expressed no opinion on whether the underlying accounting method change is
actually valid, only on the extension.

Ruling snapshot

• Question: Should a taxpayer whose preparer inadvertently failed to attach the original Form 3115 to a timely return get an extension of time to file it?
• Outcome: Approved (45-day extension granted under § 301.9100-3)
• Key authorities: Treas. Reg. §§ 301.9100-1, 301.9100-3; Rev. Proc. 2015-13; Rev. Proc. 2024-23; IRC § 446(e); IRC § 481(a)

Full text (IRS public release)

 Internal Revenue Service                                        Department of the Treasury
                                                                 Washington, DC 20224

 Number: 202629014                                               Third Party Communication: None
 Release Date: 7/17/2026                                         Date of Communication: Not Applicable
 Index Number: 9100.00-00
                                                                 Person To Contact:
 -----------------                                               ---------------------, ID No. -----------------
 ----------------------------------------                        Telephone Number:
 ---------------------------                                     --------------------
 --------------------------------                                Refer Reply To:
                                                                 CC:ITA:B08
                                                                 PLR-120459-25
                                                                 Date:
                                                                 April 23, 2026




                                                   LEGEND

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

Accounting Firm =                  --------------------------

State =                            -------------

Date 1 =                           --------------------------

Date 2 =                           ---------------------------

Date 3 =                           --------------------------

Date 4 =                           ----------------------

Date 5 =                           --------------------------
Month 1 =                          ------------------

Year 1 =                           ------------------------------------------------

Year 2 =                           ------------------------------------------------

Year 3 =                           ------------------------------------------------

Organization Year =                -------
PLR-120459-25                                        2

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

This letter responds to Taxpayer’s request for a letter ruling dated Date 1. Taxpayer
requests relief under sections 301.9100-1 and 301.9100-31 of the Procedure and
Administration Regulations for an extension of time to file the original Form 3115,
Application for Change in Accounting Method, for Year 3. Taxpayer should have filed
this Form 3115, pursuant to section 6.03(1)(a)(i) of Rev. Proc. 2015-13, 2015-5 I.R.B.
419, on or before Date 2.

                                                FACTS

According to the information and representations provided, Taxpayer, a limited liability
company classified as a partnership for federal tax purposes, was formed on Date 3 in
State. As part of its operations, Taxpayer leases vehicles from a third-party lessor
through either finance leases or operating leases. For Year 1 and Year 2, Taxpayer
incorrectly treated certain leased vehicles as owned by Taxpayer and financed through
the leases. Taxpayer determined that it should have treated each vehicle as owned by
the third-party lessor.

Taxpayer has engaged Accounting Firm to assist in preparing Taxpayer’s Form 1065
since Organization Year. Taxpayer engaged Accounting Firm to prepare, and file, the
Form 3115 with respect to the treatment of the vehicle leases which had been
improperly accounted for. Accounting Firm prepared this Form 3115 for Year 3 using
the automatic consent procedures of Rev. Proc. 2015-13 and Rev. Proc. 2024-23,
2024-23 I.R.B. 1334.

Accounting Firm submitted a copy of the Form 3115 to the Internal Revenue Service in
accordance with Rev. Proc. 2015-13 on Date 4. Accounting Firm later filed Taxpayer’s
Form 1065 on Date 5, after timely filing Form 7004, Application for Automatic Extension
of Time To File Certain Business Income Tax, Information, and Other Returns. As a
result of the accounting method change for Tax Year 3, the Taxpayer recorded a
section 481(a) adjustment and included one-fourth of such adjustment as income on its
return for Tax Year 3 to account for the difference between the depreciation and interest
expense previously deducted and the lease payments that would have been allowed for
Tax Year 1 and Tax Year 2.

In Month 1, Accounting Firm discovered that, through inadvertence, it had failed to
upload the original Form 3115 to Taxpayer’s timely electronically filed Form 1065. See
section 6.03(1)(a)(i)(A) of Rev. Proc. 2015-13. Accounting Firm subsequently submitted
this request for an extension of time to file Taxpayer’s original Form 3115.




1 Unless otherwise specified, all “section” references are to sections of the Internal Revenue Code (Code)

and all “§” references to sections of the Treasury Regulations (26 CFR Part 1) or (26 CFR Part 301).
PLR-120459-25                                3

                                   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

The information submitted by Taxpayer demonstrates to the satisfaction of the
Commissioner that it had acted reasonably and in good faith, and that granting an
extension of time to make the desired regulatory election would not prejudice the
interests of the Government. Accordingly, Taxpayer is granted 45 calendar days from
the date of this letter to file the original Form 3115 (identical to the duplicate copy
already filed with the Service). Please attach a copy of this letter ruling to the amended
return.
PLR-120459-25                                  4

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, regarding the accounting method change Taxpayer has attempted to make,
including whether it is eligible to be made under the automatic consent procedures of
Rev. Proc. 2015-13 and Rev. Proc. 2024-23, or whether Taxpayer otherwise meets the
requirements of Rev. Proc. 2015-13 to make accounting method changes using Rev.
Proc. 2015-13.

The ruling contained in this letter ruling is based upon facts and representations
submitted by Taxpayer, with accompanying penalty 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 regulatory election, all material
is subject to verification on examination.

This ruling is directed only to the taxpayer requesting it. 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 Taxpayer’s authorized representative.


                                           Sincerely,



                                           Frank W. Dunham III
                                           Senior Counsel, Branch 8
                                           Office of Associate Chief Counsel
                                           (Income Tax & Accounting)

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