AICPA Comment Letter on Sections 1362(b)(5) and 1362(f)

The AICPA submitted a letter urging Treasury and the IRS to establish a separate, reduced user-fee category for routine S corporation private letter ruling requests under sections 1362(b)(5) and 1362(f). In particular, the letter recommends a distinct category for section 1362(f) requests where the only reason relief is needed is that the Rev. Proc. 2013-30 three-year-and-seventy-five-day deadline has expired. The AICPA notes that current user fees are disproportionate to the straightforward nature of these cases and may discourage voluntary compliance.