The IRS today released an advance version of Rev. Rul. 2015-13 clarifying the impact that both Emancipation Day and Patriots’ Day could have on the time for filing an individual income tax return or making an estimated payment of tax when the due date for the income tax return and estimated tax payment falls on a Saturday, Sunday, or legal holiday.
Read Rev. Rul. 2015-13 [PDF 24 KB]
Prior IRS guidance, Rev. Rul. 90-5, provided rules for individuals, including those who resided in Massachusetts—who at that time were required to file their income tax returns at the Andover Service Center and send their estimated income tax payments to Pittsburgh, Pennsylvania—when April 15 fell on a weekend day, and the following Monday was Patriots’ Day, a state holiday in Massachusetts.
Taxpayers now no longer file returns at the Internal Revenue Center in Andover, Massachusetts, and Pittsburgh does not observe Patriots’ Day.
Notice 2002-12 addressed the filing requirements for individual taxpayers from several states, including Massachusetts, who were filing income tax returns in Massachusetts in a year when Patriots’ Day fell on April 15, a weekday.
Notice 2011-17 provides that Emancipation Day, an official public holiday in the District of Columbia, is a legal holiday described in section 7503.
Previously, no guidance existed covering the impact that both Emancipation Day and Patriots’ Day could have on the due date for filing and individual tax return or making an estimated payment of tax when the due date for both falls on a Saturday, Sunday, or legal holiday.
Today’s revenue ruling examines the following situation:
For purposes of the Rev. Rul. 2015-13, April 15 falls on the third Friday in April; Emancipation Day, April 16, is a legal holiday in the District of Columbia; and the following Monday, April 18, is Patriots' Day, a legal holiday in Massachusetts and Maine but not in any other state. Pursuant to DC law, when April 16 is a Saturday, the preceding day, or Friday, April 15, is the observed holiday.
The issue presented by today’s revenue ruling is: By what date must the specified acts of filing an individual income tax return and paying estimated taxes be performed if the due date for the income tax return and estimated tax payment falls on a Saturday, Sunday, or legal holiday?
Return filing due date - The District of Columbia observes Emancipation Day on Friday, April 15 when April 16 is a Saturday. This makes Monday, April 18, the ordinary due date for filing individual income tax returns.
However, in the facts presented, Monday, April 18 is the third Monday in April—the date that Massachusetts and Maine observe Patriots’ Day. Because residents of Massachusetts and Maine may elect to hand carry their income tax returns to their local IRS offices, all individuals who reside in Massachusetts and Maine have until the next succeeding day that is not a Saturday, Sunday, or legal holiday to file an income tax return.
Thus, the taxpayer has until Tuesday, April 19 to file an individual income tax return.
Installment payment of estimated tax due date - Pursuant to the facts presented, installment payments of estimated income tax by an individual resident of Massachusetts and Maine are made to a depository in Hartford, Connecticut—a state in which the third Monday in April is not a statewide legal holiday.
Accordingly, the taxpayer must make the first installment payment of estimated tax on or before the ordinary due date for income tax returns for the act to be timely. The fact that the taxpayer is a resident of Massachusetts—a state in which the third Monday in April is a statewide legal holiday—has no effect on the due date for payment of the first installment of estimated tax. Thus, the taxpayer must pay the first installment of estimated income tax on or before April 18.
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