The IRS will start accepting faxed duplicates of Form 3115, “Application for Change in Accounting Method,” on July 31, temporarily eliminating the previous requirement that the duplicates be mailed to the agency.
The temporary procedure, announced in FAQs July 29, only applies to taxpayers trying to make a change in accounting method under the automatic change procedure, and excludes nonautomatic change requests, according to the IRS.
“Taxpayers will still need to submit two copies of the Form 3115 to the IRS,” according to the FAQs. “Taxpayers must continue to file Form 3115 with their tax return (including extensions). However, instead of mailing the duplicate paper copy of Form 3115 to the IRS in Ogden, Utah, taxpayers can now fax it to 844-249-8134.”
The procedure is in place until further notice, and filers who have already mailed the duplicate copy to the IRS in the 2020 calendar year shouldn’t fax a second duplicate copy, the agency said.
“The IRS will not provide a confirmation or receipt [of the fax]. Please check your fax transmission log to verify that all the Form 3115 pages were sent,” the FAQs say.
Ryan Corcoran with RSM US LLP said that “taxpayers appreciate the flexibility in the choice of filing the duplicate copy of an automatic Form 3115, as many are wary to venture to the post office, UPS, or Fed Ex to mail the duplicate copy to Ogden.″ He added, however, that the IRS “should clarify whether a taxpayer’s fax transmission log will suffice as an acceptable proof of receipt. Taxpayers are generally advised to send the duplicate copy to Ogden using certified mail or an option that provides a proof of receipt.”
Since the onset of pandemic-related closures, the IRS and Tax Court have moved to increase electronic communications with taxpayers, practitioners, and others in the tax community.
The IRS issued guidance in May (Rev. Proc. 2020-29, 2020-21 IRB 859) allowing taxpayers to make letter ruling requests electronically. According to an agency official, that guidance applies to nonautomatic tax accounting method changes — those for which the IRS hasn’t given advance consent.
In response to the pandemic, the Tax Court announced procedures for remote trials on May 29, and has since started fulfilling court records requests from nonparties via email.