These proposed regulations extend the period for making the election under section 165(i). The election under section 165(i) allows a taxpayer to deduct a loss attributable to a federally declared disaster for the taxable year prior to the year in which the disaster occurred. These proposed regulations generally provide that the due date for making the section 165(i) election is six months after the due date for filing the taxpayer's federal income tax return for the disaster year. The proposed regulations also authorize the issuance of sub-regulatory guidance on a going-forward basis to provide the IRS with flexibility in response to future disasters.

This Revenue Procedure provides the procedures and requirements for making and revoking an election under § 165(i).

These temporary regulations extend the period for making the election under section 165(i). The election under section 165(i) allows a taxpayer to deduct a loss attributable to a federally declared disaster for the taxable year prior to the year in which the disaster occurred. These regulations generally provide that the due date for making the section 165(i) election is six months after the due date for filing the taxpayer's federal income tax return for the disaster year. The regulations also authorize the issuance of sub-regulatory guidance on a going-forward basis to provide the IRS with flexibility in response to future disasters.

This document contains proposed amendments to the regulation that provides the user fee for processing offers in compromise. The proposed amendments affect taxpayers who wish to pay their liabilities through offers in compromise. This document also provides a notice of public hearing on these proposed amendments to the regulations.