Statute start date for 7/15/20 filings

Technical topics regarding tax preparation.
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Nilodop  
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I can't find the previous post on this. Here's some current thinking.
Now that Notice 2020-23 has pushed the deadline for returns and payments due between April 1 and July 15 to July 15, what is the new starting point for the statute of limitation? Is it April 15 or July 15?

Sec. 6501(b)(1) states, "For purposes of this section, a return of tax imposed by this title, except tax imposed by chapter 3, 4, 21, or 24, filed before the last day prescribed by law or by regulations promulgated pursuant to law for the filing thereof, shall be considered as filed on such last day."

One could argue the law changed given the passage of legislation such as the Families First Coronavirus Response Act, P.L. 116-127 and the Coronavirus Aid, Relief, and Economic Security (CARES) Act, P.L. 116-136), and the release of Notice 2020-23. However, will these changes rise to the level of "by law or regulations promulgated"? It's not clear yet.
https://www.thetaxadviser.com/newslette ... ontent=Def

It also discusses some other issues.
 

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