Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic
Notice 2020-17
I. PURPOSE
On March 13, 2020, the President of the United States issued an emergency
declaration under the Robert T. Stafford Disaster Relief and Emergency Assistance Act
in response to the ongoing Coronavirus Disease 2019 (COVID-19) pandemic
(Emergency Declaration). The Emergency Declaration instructed the Secretary of the
Treasury “to provide relief from tax deadlines to Americans who have been adversely
affected by the COVID-19 emergency, as appropriate, pursuant to 26 U.S.C. 7508A(a).”
Pursuant to the Emergency Declaration, this notice provides relief under section
7508A(a) of the Internal Revenue Code for the persons described in section III of this
notice that the Secretary of the Treasury has determined to be affected by the COVID19 emergency.
II. BACKGROUND
Section 7508A provides the Secretary of the Treasury or his delegate (Secretary)
with authority to postpone the time for performing certain acts under the internal
revenue laws for a taxpayer determined by the Secretary to be affected by a Federally
declared disaster as defined in section 165(i)(5)(A). Pursuant to section 7508A(a), a
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period of up to one year may be disregarded in determining whether the performance of
certain acts is timely under the internal revenue laws.
III. GRANT OF RELIEF
The Secretary has determined that any person with a Federal income tax
payment due April 15, 2020, is affected by the COVID-19 emergency for purposes of
the relief described in this section III (Affected Taxpayer).
For an Affected Taxpayer, the due date for making Federal income tax payments
due April 15, 2020, in an aggregate amount up to the Applicable Postponed Payment
Amount, is postponed to July 15, 2020. The Applicable Postponed Payment Amount is
up to $10,000,000 for each consolidated group (as defined in §1.1502-1) or for each
C corporation that does not join in filing a consolidated return. For all other Affected
Taxpayers, the Applicable Postponed Payment Amount is up to $1,000,000 regardless
of filing status. For example, the Applicable Postponed Payment Amount is the same
for a single individual and for married individuals filing a joint return. In both instances
the Applicable Postponed Payment Amount is up to $1,000,000.
The relief provided in this section III is available solely with respect to Federal
income tax payments (including payments of tax on self-employment income) due on
April 15, 2020, in respect of an Affected Taxpayer’s 2019 taxable year, and Federal
estimated income tax payments (including payments of tax on self-employment income)
due on April 15, 2020, for an Affected Taxpayer’s 2020 taxable year. The Applicable
Postponed Payment Amounts described in this section III include, in the aggregate, all
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payments described in the preceding sentence due on April 15, 2020 for such Affected
Taxpayers.
No extension is provided in this notice for the payment or deposit of any other
type of Federal tax, or for the filing of any tax return or information return.
As a result of the postponement of the due date for making Federal income tax
payments up to the Applicable Postponed Payment Amount from April 15, 2020, to July
15, 2020, the period beginning on April 15, 2020, and ending on July 15, 2020, will be
disregarded in the calculation of any interest, penalty, or addition to tax for failure to pay
the Federal income taxes postponed by this notice. Interest, penalties, and additions to
tax with respect to such postponed Federal income tax payments will begin to accrue on
July 16, 2020. In addition, interest, penalties and additions to tax will accrue, without
any suspension or deferral, on the amount of any Federal income tax payments in
excess of the Applicable Postponed Payment Amount due but not paid by an Affected
Taxpayer on April 15, 2020.
Affected Taxpayers subject to penalties or additions to tax despite the relief
granted by this section III may seek reasonable cause relief under section 6651 for a
failure to pay tax or seek a waiver to a penalty under section 6654 for a failure by an
individual or certain trusts and estates to pay estimated income tax, as applicable.
Similar relief with respect to estimated tax payments is not available for corporate
taxpayers or tax-exempt organizations under section 6655.
