IRS grants 45 days to file a duplicate Form 3115

Plain-English summary

A partnership's representative tried to fax the duplicate copy of Form 3115 after electronically filing the partnership's return with the original form attached. The fax failed, but the representative mistakenly believed that a successful transmission sheet for another taxpayer showed that the duplicate had been filed. The IRS granted the partnership 45 calendar days from the ruling date to file the duplicate Form 3115 for accounting method changes involving section 263A, accrued bonuses, accrued vacation pay, and accrued commissions. The relief was granted under the regulatory election relief rules because the requirements of Treas. Reg. §§ 301.9100-1 and 301.9100-3 were satisfied. The ruling did not determine whether the accounting method changes themselves qualified under the applicable automatic consent procedures.

Ruling snapshot

• Question: May the partnership receive more time to file the duplicate Form 3115 required for its accounting method changes?
• Outcome: Approved, with 45 calendar days from the letter date to file the duplicate copy.
• Key authorities: IRC §§ 263A and 446(e); Treas. Reg. §§ 301.9100-1 and 301.9100-3; Rev. Proc. 2015-13.

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury
Washington, DC 20224

Number: 202636012
[Third Party Communication:
Release Date: 9/4/2026
Date of Communication: Month DD, YYYY]
Index Number: 9100.00-00, 9100.10-00
Person To Contact:
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Telephone Number:
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Refer Reply To:
CC:ITA:B06
PLR-120220-25
Date:
June 09, 2026

Legend:

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

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

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

Date B = ---------------------------

Date C = -------------------------

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

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

This ruling responds to a letter that was submitted by Taxpayer’s representative, CPA. 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 the duplicate copy of a Form 3115, Application for Change in Accounting Method. Taxpayer should have filed this Form 3115, pursuant to section 6.03(1)(a)(1) of Rev. Proc. 2015, 13, 2015-5 I.R.B. 419, on or before Date A.

FACTS

Taxpayer represents the following facts:

Taxpayer engaged CPA to prepare and file Taxpayer’s federal income tax return (Form 1065, U.S. Return of Partnership Income) and related accounting method changes for
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Year 1. Specifically, Taxpayer engaged CPA to prepare and file accounting method changes with respect to section 263A of the Internal Revenue Code, accrued bonuses, accrued vacation pay, and accrued commissions under the automatic consent procedures pursuant to Rev. Proc. 2015-13 and Rev. Proc. 2025-23, 2025-24 I.R.B. 1476.

Taxpayer timely filed Form 7004, Application for Automatic Extension of Time to File Certain Business Income Tax, Information, and Other Returns, which provided Taxpayer an extension until Date A to file its Form 1065 for Year 1.

In completing its duties, CPA electronically filed Taxpayer’s Form 1065, with the Form 3115 attached on Date A. Also on Date A, CPA attempted to submit the duplicate copy of the Form 3115, pursuant to section 6.03(1)(a)(i)(B) of Rev. Proc. 2015-13, via fax1. The transmission, however, failed. CPA had successfully transmitted another facsimile for a different taxpayer to the same IRS number on Date A and CPA inadvertently mistook the successful transmission sheet for that fax for successful submission of the duplicate copy of Taxpayer’s Form 3115. On Date B, CPA realized that duplicate copy of Taxpayer’s Form 3115 had not been submitted. On Date C, CPA submitted this request for an extension of time to file the duplicate copy of Taxpayer’s Form 3115.

RULING REQUESTED

Taxpayer requests an extension of time pursuant to §§ 301.9100-1 and 301.9100-3 to file the duplicate copy of the Form 3115 required by Rev. Proc. 2015-13 to change Taxpayer’s accounting methods with respect to section 263A, accrued bonuses, accrued vacation pay, and accrued commissions.

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 Rev. Proc. 2015-13 has obtained the consent of the Commissioner to change its method of accounting under section 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 duplicate copy of the Form 3115. 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.

1
Pursuant to section 9.06(2) of Rev. Proc. 2025-1, 2025-1 I.R.B. 1.
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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 required duplicate copy of the Form 3115 (identical to the original copy already filed with the Service) changing Taxpayer’s methods of accounting with respect to section 263A, accrued bonuses, accrued vacation pay, and accrued commissions for Year 1. Please attach a copy of this letter ruling to the 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 attempted to make are eligible to be made under the automatic consent procedures of Rev. Proc. 2015-13 and Rev. Proc. 2025-23, or whether Taxpayer otherwise meets the requirements of Rev. Proc. 2015-13 to make accounting method changes using the Rev. Proc. 2015-13. Further, we express no opinion regarding the propriety of Taxpayer’s proposed methods of accounting with respect to section 263A, accrued bonuses, accrued vacation pay, and accrued commissions.

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 6100(k)(3) provides that it may not be used or cited as precedent.
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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
Assistance to Branch Chief, Branch 6
Office of Associate Chief Counsel
(Income Tax & Accounting)

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