NTA Blog: Lookback Rule: The IRS Fixes The Refund Trap For The Unwary

As I recently stated in my February 27, 2023, blog (NTA Blog: Lookback Rule: The IRS Fixes the Refund Trap for the Unwary), the IRS issued Notice 2023-21 providing taxpayers a longer lookback period when determining the amount of a claim for credit or refund that can be allowed for tax years (TYs) 2019 and 2020. The issuance of this notice addressed the mismatch between the time for filing a claim for credit or refund and the three-year lookback period caused by postponing certain filing deadlines for filing seasons 2020 and 2021, which would result in the denial of timely claims for credit or refund for those taxpayers who took advantage of the postponed deadlines and who had withholding or estimated payments. (In response to the COVID-19 pandemic, the IRS postponed the filing deadlines for TY 2019 to July 15, 2020, and for TY 2020 to May 17, 2021.) This discussion largely focuses on the more esoteric and immediate issues of filing claims for credit or refund for TY 2019, but the same analysis will apply to individuals who file timely claims for credit or refund in 2024 for TY 2020.

Key Takeaway: Many taxpayers still have time to file their original or amended 2019 return and claim a credit or refund, including refundable credits such as the Earned Income Tax Credit (EITC), Additional Child Tax Credit, or the American Opportunity Tax Credit.

The lookback rule tends to generate confusion, and questions continue to arise about when the relief provided under Notice 2023-21 applies. I thought it would be helpful to walk through a few examples.

Example 1
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