Why does the IRS need proof if the extension is automatic?

The IRS says it needs to verify eligibility and needs the dates you served or worked in a qualified area so it can update your account.

What documents should I send?

Form 15109 asks for your entry and exit dates for the qualified area and a copy of military orders, or a Letter of Authorization for civilians, according to the IRS manual.

What if I never served in a combat zone?

IRS procedures say that if you tell the IRS you did not serve in a combat zone that year, the incorrect combat zone coding is allowed to drop off. Check whether your return was marked by mistake and correct it.

What happens if I do not respond?

The IRS says you will not receive tax deferment benefits if it does not receive Form 15109 by the due date. Its manual says the combat zone coding is reversed if no response arrives within 70 days.

Does this apply to civilians?

IRC 7508 covers individuals serving in the Armed Forces or serving in support of them in a designated combat zone, and those deployed outside the United States in a designated contingency operation. Civilians send a Letter of Authorization instead of military orders.

IRS CP04: Proof Needed for Combat Zone Tax Deferment

CP04 asks service members and support personnel to prove combat zone dates on Form 15109 to keep tax deferment. What to send and when to send it.

What CP04 means

CP04 is a request for proof. Your tax return said you or your spouse served in a combat zone, a qualified contingency operation, or a hazardous duty area during the year on the notice. The IRS wants documentation before it gives you the tax deferment that comes with that service.

The IRM's title for the notice says it plainly: Request for Proof of Military Status or Eligibility for Tax Relief Provisions Under Combat Zone/Contingency Operation Criteria. The IRS mails Form 15109, Request for Tax Deferment, with it.

This is not an audit, and it is not a bill. It is the IRS asking you to show the dates so your account gets the protection the law provides.

Why you got it

When a return is marked "Combat Zone" and the IRS has no valid Department of Defense service dates on your account, the system generates CP04. That is the trigger described in IRM 5.19.10.6.5.5. Sometimes the dates simply have not been reported to the IRS yet. Sometimes the return was marked by mistake. Either way, the IRS needs your answer.

What the deferment is worth

IRC 7508 is one of the most generous timing rules in the Code. For an individual serving in the Armed Forces, or serving in support of them, in a designated combat zone, or deployed outside the United States in a designated contingency operation, the law disregards the period of service, any continuous qualified hospitalization for injury from that service, and the next 180 days after that.

During that disregarded time, the clock stops on a long list of deadlines. Section 7508(a)(1) covers filing returns, paying tax, filing Tax Court petitions, filing refund claims, bringing refund suits, and also the IRS's own deadlines for assessment and collection. The IRS describes it as an extension for filing returns, paying taxes, filing claims for refund, and taking other actions.

That is the benefit at stake. If the IRS cannot verify your dates, your account may be treated as if no extension applied. That can mean late filing and late payment penalties and interest you would otherwise not owe.

Congress gave you the time. CP04 is the IRS asking you to prove when the clock should stop.

The deadline

Send your completed Form 15109 and supporting documents by the due date on your CP04. The IRS says that if it does not receive the form by then, you will not receive tax deferment benefits. The IRM adds that if no response arrives within 70 days, the combat zone indicators on the account are systemically reversed.

If you are still deployed and cannot respond, someone with authority can help. A spouse or other representative with a valid power of attorney can communicate with the IRS for you. Get that authorization in place before you leave if you can.

How much extra time you actually get

Publication 3 explains the math in two steps. First, your deadline is extended for 180 days after the later of your last day in the combat zone or contingency operation, or the last day of any continuous qualified hospitalization for an injury from that service. Second, you add the number of days that were left to take the action when you entered the combat zone. If you entered before the time to act even began, you get the entire period added.

Take a filing deadline as an example. If you deployed before the filing season opened and stayed through it, the whole filing period is added on top of the 180 days after you return. That is a lot of time, and it is exactly why the IRS wants your real dates on file.

Spouses get the extension too, with limits

Publication 3 says spouses of individuals who served are entitled to the same deadline extensions, with two exceptions. The extension does not apply to a spouse for any tax year beginning more than 2 years after the area stops being a combat zone or the operation stops qualifying. And it does not apply to a spouse for any period the service member is hospitalized in the United States for injuries from that service. If you file jointly, the dates on Form 15109 matter for both of you.

What to send

According to the IRS manual, Form 15109 asks for the entry and exit dates for the qualified area and a copy of your military orders. Civilians supporting the Armed Forces send a Letter of Authorization instead of orders. Include:

The completed and signed Form 15109.
Orders, or the Letter of Authorization for civilians, showing the qualified area.
Entry and exit dates for each deployment during the year.
The type of service (military or civilian) and the organization.
Hospitalization records if you are claiming continuous qualified hospitalization.

How to send it

The IRS gives three ways:

Document Upload Tool. Use the access code printed on your CP04.
Fax. Send to the fax number on Form 15109.
Mail. Send to the address at the top of your notice.

Keep copies of everything and proof of when you sent it. The IRS manual also lists 800-908-0368 for CP04 phone responses. Confirm the number on your own notice before you call.

What to do now

Check whether the return was supposed to claim combat zone relief at all. If it was marked by mistake, tell the IRS. Its procedures say it lets the incorrect coding drop off when you confirm you did not serve in a combat zone that year.
Gather orders and dates for each deployment.
Complete Form 15109 and submit it by the due date.
Review Publication 3, Armed Forces' Tax Guide, for the details on which areas and operations qualify.
If you owe a balance, keep watching your mail. The deferment affects when penalties and interest apply, not whether the tax is owed.

What not to do

Do not assume your unit or finance office told the IRS. CP04 exists because the IRS did not have your dates.

Do not ignore the notice because you are home now. The 180-day window after service is calculated from your actual dates, so the IRS needs them.

Do not file a duplicate return in response. Answer the notice.

Combat zone pay is a separate question

The deferment in IRC 7508 is about time. Whether your pay is excluded from income is a different rule, found in IRC 112. CP04 is about the timing protection. If you have questions about how your pay was reported, compare your Form W-2 with your leave and earnings statements and review Publication 3.

One more point for service members who claim the Earned Income Tax Credit. IRC 32(c)(2) lets you elect to treat combat pay excluded under IRC 112 as earned income for that credit. Whether the election helps depends on your numbers, so run it both ways.

The law behind CP04

IRC 7508(a) disregards the period of qualifying service, continuous qualified hospitalization, and the next 180 days for a long list of tax deadlines, both yours and the IRS's. IRM 5.19.10.6.5.5 explains when CP04 issues, what Form 15109 requests, and what happens if no response arrives. Publication 3 is the IRS's plain-language guide for service members.

If you served and the IRS is treating your account as if you didn't, call us at (813) 229-7100.