N-23-21, lengthens the lookback period for refund claims for returns with certain due dates

In response to COVID-19, the Service, pursuant to IRC ? 7508A, issued Notice 2020-23 and Notice 2021-21 to postpone certain return filing due dates; however, the Notices did not lengthen the lookback period for refund claims for such returns under section 6511(b)(2)(A). Consequently, some payments that taxpayers made ? including estimated and withheld income taxes deemed paid on April 15 of each year for calendar-year taxpayers ? will fall outside of the lookback period if taxpayers filed their returns after April 15.? If the payments fall outside of the lookback period, then, despite filing a timely refund claim, a taxpayer cannot be refunded those payments. Using the Secretary?s disaster relief authority under section 7508A(a), this notice disregards the periods from April 15, 2020 to July 15, 2020, and from April 15, 2021 to May 17, 2021, in determining the beginning of the lookback period to align the lookback periods with the postponed return filing due dates.

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