HealthCare Tax Credit - Claiming the HCTC for previous tax years

[Eddie66]

I filed an amended tax return for tax year 2019 (on May 14, 2021) to claim the HCTC, using TurboTax to generate the 1040X, along with the required IRS forms 8453 and 8885.  The process was smooth and the entire amended return (with the required forms and supporting documentation as detailed within the forms’ instructions) was submitted to the IRS within the 3 year timeline for an amended return for 2019.  

The IRS disallowed the claim for the HCTC, stating that I filed too late as the claim has to be filed by the date due for the tax year, that being 4/15/2020 for tax year 2019, or later if you requested an extension.  This decision was detailed within their 105C letter received in August 2022.

My questions are:

A - is the IRS wrong in their decision to disallow my claim for the HCTC through an amended return filed within the 3 year timeframe, but after the latest due date for the initial filing of the tax return for 2019?

B- why does the TurboTax software for tax year 2019 allow the HCTC to be claimed through an amended return that is generated well after the due date for the initial filing of the tax return for tax year 2019, which is April 15, 2020 or the date of extension if you requested an extension? This capability implies that TurboTax 2019 software has coding that is in direct conflict with the IRS code for claiming the HCTC through a 1040X “after” the latest filing date for the return for tax year 2019 (either April or October 2020).

can anyone provide clarification or guidance in this situation?

 Thanks in advance!

[Critter-3 · Accepted solution]

A - is the IRS wrong in their decision to disallow my claim for the HCTC through an amended return filed within the 3 year timeframe, but after the latest due date for the initial filing of the tax return for 2019?   The IRS is correct ... that credit has a deadline. It must be filed by the return filing deadline which for a 2019 return was 7/15/2020 or 10/15/2020 if you requested an extension. 

B- why does the TurboTax software for tax year 2019 allow the HCTC to be claimed through an amended return that is generated well after the due date for the initial filing of the tax return for tax year 2019, which is April 15, 2020 or the date of extension if you requested an extension? This capability implies that TurboTax 2019 software has coding that is in direct conflict with the IRS code for claiming the HCTC through a 1040X “after” the latest filing date for the return for tax year 2019 (either April or October 2020).  This is something that the program doesn't take into consideration in any program updates   and because so few clients use this credit I doubt that TT will correct this issue for older tax years in the future either.  

[NCperson]

@Critter-3 @Eddie66 - one minor typo.... the 2019 filing deadline was 7/15/20, due to the pandemic 😊

the extension deadline was still 10/15/20.