Relief for Taxpayers Affected by the 2023-2024 Terroristic Action in the State of Israel

Notice 2024-72

SECTION I. PURPOSE

This notice provides relief under section 7508A of the Internal Revenue Code1 for
persons that the Secretary of the Treasury (Secretary) has determined to be affected by
the terroristic action in the State of Israel throughout 2023 and 2024. The Department
of the Treasury and the Internal Revenue Service (IRS) may provide additional relief in
the future. For taxpayers who were “Affected Taxpayers” for purposes of Notice 2023-
71, 2023-44 IRB 1191 (October 30, 2023), the separate determination of terroristic
action and grant of relief set forth in this notice will also postpone taxpayer acts and
government acts already postponed by Notice 2023-71 if the taxpayer is eligible for
relief under both notices.

SECTION II. BACKGROUND
Section 7508A(a) provides the Secretary or her delegate with authority to
postpone the time (up to one year) for performing certain acts under the internal

revenue laws for a taxpayer determined by the Secretary or her delegate to be affected
by a terroristic or military action as defined in section 692(c)(2). Section 692(c)(2)
defines a terroristic action as “any terroristic activity which a preponderance of the
evidence indicates was directed against the United States or any of its allies.”
Section 4.01(1) of Revenue Procedure 2004-26, 2004-1 C.B. 890, provides that
prior to publishing a determination that an event outside the United States constitutes a
terroristic action within the meaning of section 692(c)(2), the Secretary or her delegate
will ascertain whether the Department of State and the Department of Justice believe
that a preponderance of the evidence indicates that the event resulted from terrorist
activity directed against the United States or its allies. On September 30, 2024, in
accordance with the procedures described in Rev. Proc. 2004-26, the Secretary
determined that the terrorist activity throughout 2023 and 2024 against the State of
Israel constitutes terroristic action within the meaning of section 692(c)(2).
SECTION III. GRANT OF RELIEF
With respect to taxpayers described in section III.A of this notice (affected
taxpayers), this notice postpones the due dates for the actions described in section III.B
and III.C of this notice until September 30, 2025.
A. Affected Taxpayers
Section 301.7508A-1(d)(1) describes several types of “affected taxpayers”
eligible for relief under section 7508A. The Secretary has determined that the following
types of taxpayers are affected taxpayers with respect to the terroristic action eligible for
the relief provided in this notice:

• Any individual whose principal residence, and any business entity or sole

proprietor whose principal place of business, is located in the State of Israel, the
West Bank or Gaza (covered area);

• Any individual affiliated with a recognized government or philanthropic
  organization and who is assisting in the covered area, such as a relief worker;
• Any individual, business entity or sole proprietor, or estate or trust whose tax
  return preparer or records necessary to meet a deadline for postponed acts are
  located in the covered area;
• Any spouse of an affected taxpayer, solely with regard to a joint return of two
  married individuals; and
• Any individual visiting the covered area who was killed, injured, or taken hostage
  as a result of the terroristic action.
  The IRS automatically identifies taxpayers whose principal residence or principal place
  of business is located in the covered area based on previously filed returns and applies
  relief. Affected taxpayers whose principal residence or principal place of business is not
  located in the covered area should call the IRS disaster hotline at (866) 562-5227 to
  request relief. Alternatively, international callers may call (267) 941-1000.
  B. Postponement of Due Dates with Respect to Certain Taxpayer Acts
  Affected taxpayers have until September 30, 2025, to file tax returns, make tax
  payments, and perform certain time-sensitive acts listed in § 301.7508A-1(c)(1) and
  Revenue Procedure 2018-58, 2018-50 IRB 990 (December 10, 2018), that are due to
  be performed on or after September 30, 2024, and before September 30, 2025. Any
  taxpayer acts that are due to be performed on or after September 30, 2024, and before
  September 30, 2025, are postponed until September 30, 2025. These acts include, but are not limited to:

• Filing any return of income tax, estate tax, gift tax, generation-skipping transfer
  tax, excise tax (other than firearms tax), harbor maintenance tax, or employment
  tax;
• Paying any income tax, estate tax, gift tax, generation-skipping transfer tax,
  excise tax (other than firearms tax), harbor maintenance tax, or employment tax,
  or any installment of those taxes;
• Making contributions to a qualified retirement plan;
• Filing a petition with the Tax Court;
• Filing a claim for credit or refund of any tax; and
• Bringing suit upon a claim for credit or refund of any tax.
  This is not an exhaustive list. For further information, see § 301.7508A-1(c)(1) and Rev.
  Proc. 2018-58.
  C. Postponement of Due Dates with Respect to Certain Government Acts
  This notice also provides the IRS with additional time to perform certain timesensitive actions with respect to affected taxpayers. Any government acts described in
  § 301.7508A-1(c)(2) that are due to be performed on or after September 30, 2024, and
  before September 30, 2025, are postponed until September 30, 2025. These acts
  include:
• Assessing any tax;
• Giving or making any notice or demand for the payment of any tax, or with
  respect to any liability to the United States in respect of any tax;
• Collecting by the IRS, by levy or otherwise, of the amount of any liability in respect of any tax; and

• Bringing suit by the United States, or any officer on its behalf, in respect of any
  liability in respect of any tax; and allowing a credit or refund of any tax.
  SECTION IV. INTERACTION WITH NOTICE 2023-71
  Notice 2023-71 provided taxpayers affected by the October 7, 2023 Terrorist
  Attacks against the State of Israel until October 7, 2024, to perform acts due to be
  performed on or after October 7, 2023, and before October 7, 2024. Time-sensitive
  acts postponed by Notice 2023-71 are not due to be performed until after the beginning
  of the postponement period provided by this notice. Accordingly, taxpayers eligible for
  relief under Notice 2023-71 who are also eligible for relief under this notice have until
  September 30, 2025, to perform the time-sensitive acts that were postponed by Notice
  2023-71. Taxpayers eligible for relief under Notice 2023-71 who are not also eligible for
  relief under this notice have until October 7, 2024, to perform the time-sensitive acts
  postponed by Notice 2023-71. Government acts that were postponed by Notice 2023-
  71 until October 7, 2024, and that are described in section III.C., are also postponed by
  this notice until September 30, 2025, for taxpayers that are eligible for relief under
  Notice 2023-71 and this notice.
  SECTION V. DRAFTING INFORMATION
  The principal author of this notice is the Office of Associate Chief Counsel
  (Procedure and Administration). For further information regarding this notice, you may
  call (202) 317-3400 (not a toll-free number).

Tax Assistant

Suresh holds a Master of Commerce (M.Com) degree and is a dedicated personal finance researcher and writer. Combining his advanced academic background in commerce with deep industry research, he covers complex topics like taxation, banking systems, credit analysis, and personal finance strategies. As the founder of Tax Assistant (taxassistant.org), Suresh is committed to translating complicated financial guidelines and economic data into simple, accurate, and actionable educational resources for everyday readers.