missed March 16 deduction due date

Any chance the IRS would provide relief for a plan sponsor (partnership) that filed their 2019 partnership return on 3/16/20 but was unable to fund the pension deductions reported on the return?

An extension was not filed.

Given the situation with the corona virus that has been developing over the past two weeks & the fact that they announced today that 4/15 filers have a 90-day extension to file their returns

would the IRS permit the plan sponsor to keep the pension deductions if the deposits are made as soon as possible?

Is there any recourse the plan sponsor can take to keep their deductions? VCP or SCP?

I would not count on any relief.  They are probably SOL.

Thanks. As a TPA, I hate to give the advise of letting sleeping dogs lie. But I'm sure that's the response I'll get from the plan sponsor & accountants.

For now, we'll wait & see if any further taxpayer relief is issued.

3 hours ago, B21 said:

Thanks. As a TPA, I hate to give the advise of letting sleeping dogs lie. But I'm sure that's the response I'll get from the plan sponsor & accountants.

For now, we'll wait & see if any further taxpayer relief is issued.

 

Well, it is a deductibility issue, and what was reported on the 1120s, it’s not really a plan issue, so it is up to the sponsor and their tax accountant how to deal with it. These sorts of decisions are made all the time.  If under audit the deduction is denied for 2019, it’s probably deductible in 2020.  So it’s a timing issue, with maybe some penalties and interest.  They don’t have the same concerns we have.  When a plan has an error it is potentially disqualifying, thereby nuking the whole plan.  OTOH if something is wrong on the 1120, the whole Corp is not nuked.

On 3/21/2020 at 5:19 PM, shERPA said:

Well, it is a deductibility issue, and what was reported on the 1120s, it’s not really a plan issue, so it is up to the sponsor and their tax accountant how to deal with it. These sorts of decisions are made all the time.  If under audit the deduction is denied for 2019, it’s probably deductible in 2020.  So it’s a timing issue, with maybe some penalties and interest.  They don’t have the same concerns we have.  When a plan has an error it is potentially disqualifying, thereby nuking the whole plan.  OTOH if something is wrong on the 1120, the whole Corp is not nuked.

They could take the deduction (as they apparently did), but to quote an ex-president: "That would be wrong".

However, the odds of them being caught are most likely less than 1%.  And it is a timing issue for the return (as noted, not a plan level issue), so let them decide.