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Form 990-N -- when available?

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Stan Brown

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Feb 2, 2023, 6:41:15 PM2/2/23
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I'm on the board of a small nonprofit, and our treasurer is trying to
file a 990-N (the postcard-sized return, only filable on the IRS
website, electronically). But on the page
<https://www.irs.gov/charities-non-profits/annual-electronic-filing-
requirement-for-small-exempt-organizations-form-990-n-e-postcard>
there's a banner:

"Service Outage
This service is unavailable. Check back later. Thank you for your
patience."

And <https://sa.www4.irs.gov/epostcard/> has a page title of "Planned
outage" with this text:

"This service will be unavailable due to system maintenance. We
apologize for any inconvenience. If more information is available,
you can find it by selecting the service from the Tools page."

"Tools page" is a link to <https://www.irs.gov/help/tools>, which
doesn't even mention nonprofits.

This has been the situation for at least two weeks.

Anyone know when -- or if -- form 990-N will be available for filing?
I know we have the option to file form 990 instead, but that's more
work, and since it would be on paper we would worry about when (or
if) the IRS receives it.

--
Stan Brown, Tehachapi, California, USA https://BrownMath.com/
Shikata ga nai...

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Adam H. Kerman

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Feb 3, 2023, 10:04:40 AM2/3/23
to
Stan Brown <the_sta...@fastmail.fm> wrote:

>I'm on the board of a small nonprofit, and our treasurer is trying to
>file a 990-N (the postcard-sized return, only filable on the IRS
>website, electronically). But on the page
><https://www.irs.gov/charities-non-profits/annual-electronic-filing-
>requirement-for-small-exempt-organizations-form-990-n-e-postcard>
>there's a banner:

>"Service Outage
>This service is unavailable. Check back later. Thank you for your
>patience."

>And <https://sa.www4.irs.gov/epostcard/> has a page title of "Planned
>outage" with this text:

>"This service will be unavailable due to system maintenance. We
>apologize for any inconvenience. If more information is available,
>you can find it by selecting the service from the Tools page."

>"Tools page" is a link to <https://www.irs.gov/help/tools>, which
>doesn't even mention nonprofits.

>This has been the situation for at least two weeks.

>Anyone know when -- or if -- form 990-N will be available for filing?

It's been intermitent for longer than two weeks. A friend noticed it in
early January, and I was having trouble with some of their tools during
parts of December.

Last August, IRS announced a new authentication platform. For the 990-N,
your old credentials should still work, but if they don't, you'll be
required to create an ID.me account to identify yourself.

I'm guessing this is what broke.

I don't think I used the new authentication platorm when I filed 990-N
for an organization with a June year end. I probably filed in July.

The deadline is the same as the 990, May 15 or the 15 day of the fifth
month after close of non-calendar year fiscal year. I've filed them
really late once or twice, during the 10th or 11th month. They still get
accepted. Just ask your treasurer to check on it every so often and
to have a little patience.

>I know we have the option to file form 990 instead, but that's more
>work, and since it would be on paper we would worry about when (or
>if) the IRS receives it.

Who cares when IRS receives it. This is why God invented certified mail.
In my opinion, that's a superior method for establishing timeliness than
an electronic receipt.

I'm not advising you to file a 990 or 990-EZ, which is overkill for a
small tax-exempt organization with gross receipts that are normally
$50,000 or less.

John Levine

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Feb 3, 2023, 3:25:23 PM2/3/23
to
According to Adam H. Kerman <a...@chinet.com>:
>The deadline is the same as the 990, May 15 or the 15 day of the fifth
>month after close of non-calendar year fiscal year. I've filed them
>really late once or twice, during the 10th or 11th month. They still get
>accepted. Just ask your treasurer to check on it every so often and
>to have a little patience.

Agreed. That's what I'm doing for my tiny nonprofit.

>>I know we have the option to file form 990 instead, but that's more
>>work, and since it would be on paper we would worry about when (or
>>if) the IRS receives it.

The point of 990-N is at least as much to make life easier for the IRS
as it is for non-profits. The IRS does not want a flurry of paper
forms from tiny organizations. Just wait. In the unlikely event that
the 990-N system isn't fixed by May, they're much more likely to tell
people to wait than to send paper.

The penalty for late filing of a 990 is basically nothing. After a few
years, the IRS will notice and write you a letter reminding you that
if you don't catch up, they will cancel your exempt status. Even then,
you file your late 990s, and you're all set. I look at a fair number
of 990s and I see late filed ones all the time, even for pretty big
organizations.
--
Regards,
John Levine, jo...@taugh.com, Primary Perpetrator of "The Internet for Dummies",
Please consider the environment before reading this e-mail. https://jl.ly

Adam H. Kerman

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Feb 3, 2023, 4:35:37 PM2/3/23
to
Stan Brown <the_sta...@fastmail.fm> wrote:

>I'm on the board of a small nonprofit, and our treasurer is trying to
>file a 990-N (the postcard-sized return, only filable on the IRS
>website, electronically). . . .

https://sa.www4.irs.gov/secureaccess/ui/

On this page, I'm offered different sign in methods. I don't have a
need to file a 990-N to test it, but ask your treasurer to see if he can
sign in and file.

Note that you aren't yet being forced to identify yourself with ID.me
yet and can use your old credentials.

Don't be shocked if it goes down again in a few days.

Stuart O. Bronstein

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Feb 3, 2023, 7:11:04 PM2/3/23
to
"John Levine" <jo...@taugh.com> wrote:
> According to Adam H. Kerman <a...@chinet.com>:

>>The deadline is the same as the 990, May 15 or the 15 day of the
>>fifth month after close of non-calendar year fiscal year. I've
>>filed them really late once or twice, during the 10th or 11th
>>month. They still get accepted. Just ask your treasurer to check
>>on it every so often and to have a little patience.
>
> Agreed. That's what I'm doing for my tiny nonprofit.
>
>>>I know we have the option to file form 990 instead, but that's
>>>more work, and since it would be on paper we would worry about
>>>when (or if) the IRS receives it.
>
> The point of 990-N is at least as much to make life easier for the
> IRS as it is for non-profits. The IRS does not want a flurry of
> paper forms from tiny organizations. Just wait. In the unlikely
> event that the 990-N system isn't fixed by May, they're much more
> likely to tell people to wait than to send paper.
>
> The penalty for late filing of a 990 is basically nothing. After a
> few years, the IRS will notice and write you a letter reminding
> you that if you don't catch up, they will cancel your exempt
> status. Even then, you file your late 990s, and you're all set. I
> look at a fair number of 990s and I see late filed ones all the
> time, even for pretty big organizations.

In general the IRS doesn't charge a penalty if you had good cause to
do whatever incurred the penalty. Their website not accepting the
990-N seems like pretty good cause to me.

--
Stu
http://DownToEarthLawyer.com


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Adam H. Kerman

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Feb 4, 2023, 10:08:36 AM2/4/23
to
There is no penalty for late filing 990-N, which is electronic notice
and not a tax return. There are late-filing penalties for 990 and 990-EZ
but one never hears of enforcement.

This all goes back to the Pension Protection Act of 2006. Someone in
Congress (probably John McCain) thought it was a terrible thing that IRS
maintained names of exempt organizations in the Business Master File and
not having any idea if they were still in business. The act imposed a
requirement upon tiny exempt organzations to file an annual notice
beginning in 2008. The threshold was originally was $25,000 or less in
gross receipts. The was raised to $50,000 or less. Above that, the
entity was required to file 990 or 990-EZ, which are tax returns.

Fail to give required annual notice or file tax returns for three years
in a row, IRS puts the organization on the automatic revocation list. If
recognition was obtained by determination letter, the determination
letter is no longer in force.

None of this applies to churches, which do not have an annual obligation
to file a tax return or give notice.

John Levine

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Feb 4, 2023, 10:08:36 AM2/4/23
to
It appears that Adam H. Kerman <a...@chinet.com> said:
>Stan Brown <the_sta...@fastmail.fm> wrote:
>
>>I'm on the board of a small nonprofit, and our treasurer is trying to
>>file a 990-N (the postcard-sized return, only filable on the IRS
>>website, electronically). . . .
>
>https://sa.www4.irs.gov/secureaccess/ui/
>
>On this page, I'm offered different sign in methods. I don't have a
>need to file a 990-N to test it, but ask your treasurer to see if he can
>sign in and file.

I clicked on all three of the sign-in buttons, and they all gave me
the same error page.

But, if I start at the IRS home page, click "Sign in to your account",
and a similar button on the next page, it arrives at what looks like
the same page. Now signing in with ID.me or my old IRS login works,
but it puts me in my personal account.

So then I went back to the 990-N page, clicked submit Form 990-N, and
whaddaya know, it logs me in to a page that lets me set up for 990-N.
But when I try to add my org's EIN, I get an error page.

I think I'll wait.

--
Regards,
John Levine, jo...@taugh.com, Primary Perpetrator of "The Internet for Dummies",
Please consider the environment before reading this e-mail. https://jl.ly

Stan Brown

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Feb 4, 2023, 3:04:21 PM2/4/23
to
Thanks to everyone for your replies, especially to those who
experimented and reported your results.

The TL;DR seems to be "wait a while and try again. Even if you don't
file till after the mid-May deadline, there's effectively no
penalty."

I've passed all your comments, and mu summary, to our treasurer.
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