IRS Statement and Instructions Regarding Recent CCH Software Outage

Source: IRS Senior Stakeholder Liaison Joe McCarthy

May 14, 2019

The IRS has been working closely with CCH to ease the impact on taxpayers caused by their recent software outage.

The IRS encourages these taxpayers with a May 15 deadline to file on time, if possible. Taxpayers who cannot file on time are encouraged to file for an extension.

Taxpayers affected by the CCH outage who do not file an extension and file after the deadline should include the phrase “Late filed return due to CCH Software Outage” as a statement of reasonable cause.

Potential tax returns affected by this include Forms 990, 1120, 1120S, and 1065 for some calendar year and fiscal year filers.

Specific instructions for taxpayers and preparers seeking reasonable cause penalty relief:

For Paper:

  • To clearly identify an impacted paper-filed return, please have the filer attach a separate written statement to the signed tax return that’s titled “Reasonable Cause Waiver Request - IRC 6651, Failure to File Penalty” that contains the same text noted below for the e-filed return. It must be attached to the original signed return.

For E-Filed Returns:

  • For 990s: in the Reasonable Cause Statement element of the electronic file, include the following text: “Late filed return due to CCH Software outage”
  • For 1120, 1120S, 1065: Complete the Special Condition Description element for the F1120 form family and F1065. In the "Special Condition Desc" element of the electronic file, include the following text “Late filed return due to CCH Software outage”.