A CPAR partnership filed original return on 3.16.20 after filing a valid extension prior to 3.15.20. On 9.12.20, a superseding return was filed to take bonus depreciation on QIP put into service in 2018. Subsequent to 9.12.20, the partnership discovered certain 2019 guaranteed payments were, in fact, expense reimbursements and desires to file an amended return prior to 9.30.20 under Rev Proc 2020-23. One of the requirements of Rev Proc 2020-23 is that the partnership filed a Form 1065 and furnish all required K-1s prior to 4.08.20. Please confirm that the partnership qualifies to file an amended return prior to 9.30.20 by reason of the original filing date of 3.16.20?
I believe that you are disqualified from filing an amended CPAR return by prior to September 30 because your superseding return you filed on September 12 became your “original return.” Because your original return was filed after April 8, you are disqualified.