Adequacy of Return to Start Limitations Running (Sufficient v Insufficient)

ID:
UILC:
CCA_2022112109034348
6501.04-00
Number: 202248010
Release Date: 12/2/2022
From: ---
Sent: Monday, November 21, 2022 9:03:43 AM
To: ---
Cc: ---
Bcc:
Subject: RE: Informal Legal Advice Re: EIP Non filer Portal
Hi ---,
Our position is that a $1 simplified return filed through the non-filer portal is a return, including for purposes of section 6501. The best interpretation of the language in Rev.
Proc. 2020-28 is that simplified returns are Federal income tax returns. Additionally, the analogous revenue procedure for the 2020 tax year, Rev. Proc. 2021-24, states in section 4.03 that “A simplified return is a Federal income tax return for all purposes.” 2019 and 2020 simplified returns should be treated consistently. Finally, we believe a simplified return would meet the Beard test.
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Thanks.
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