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Remedying Missed Elections, Deadlines, and Claims: Section 9100 Relief and Other Strategies to Fix Missed Elections, Deadlines, and Claims

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, March 16, 2023

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This webinar will address relief provisions available to salvage missed deadlines and elections. Our panel of tax specialists will pair commonly missed tax deadlines and elections with IRS relief that is available to mitigate the related penalties and tax consequences of these oversights.


Tax-specific deadlines are missed for various reasons. Missed tax-specific deadlines can lead to lost legal rights, forfeited tax benefits, hefty penalties, interest, and malpractice claims. Fortunately, statutory, regulatory, and/or administrative relief exists for many missed tax deadlines.

Taxpayers have various options to cure missed deadlines, including but not limited to: section 9100 relief and obtaining a private letter ruling; relief for late-filed tax returns, late-payments of tax, and late-filed claims for credits or refunds; audit reconsideration; equitable tolling; offers in compromise on the ground of doubt as to liability; correcting late-rollovers to qualified retirement plans; and broad relief available in collection due process cases. These strategies can mitigate the otherwise devastating consequences of missed elections, deadlines, and claims.

Listen as our panel of federal tax experts reviews methods available to obtain relief for many commonly missed tax-specific elections, deadlines, and claim selections.



  1. Introduction
  2. Section 9100 relief
  3. Late-filed tax returns
  4. Late payments of tax
  5. Late-filed claims for credits and refunds
  6. Correcting late rollovers under IRC Section 408(d)(3)
  7. Audit reconsideration
  8. Doubt as to liability offers in compromise
  9. Recent developments concerning equitable tolling
  10. Curing missed elections with private letter rulings
  11. Other relief to cure missed tax deadlines and elections


The panel will cover these and other critical issues:

  • Obtaining Section 9100 relief for missed elections
  • Mitigating penalties and interest on account of late-filed tax returns and late payments
  • Fixing missed claims for refund
  • Correcting late rollovers under IRC Code Section 408(d)(3)
  • Developments concerning equitable tolling and the ability of tax authorities and courts to overlook missed deadlines
  • Relief available for late-filed returns and payments
  • When seeking a PLR may be necessary or appropriate


Agostino, Frank
Frank Agostino

Agostino & Associates

Mr. Agostino is the founder and president of Agostino & Associates, P.C.  Prior to entering private practice,...  |  Read More

Sannicandro, Lawrence
Lawrence A. Sannicandro

McCarter & English

Mr. Sannicandro focuses his practice on federal and state tax controversies, including representation in audits,...  |  Read More

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