Rev. Proc. 2013-30 for S-Corp Election

[HV Ken]

Had a client file a Form 2553 to elect to be treated as an S-Corp. Client waited and filed the form after 3/15. IRS denied the election for 2014 and is recognizing the election beginning 1/1/15. Client really wants/needs this to be for 1/1/14. The IRS response says that the 2553 can be submitted pursuant to rev. proc. 2013-30 with a statement explaining reasonable cause for filing late.

Are there any suggestions on how to word this explanation such that it will be accepted for 1/1/14 consideration?

Thanks!

[michaelmars]

state that the intent was to be an S corp but there was confusion between cpa and attorney with each thinking the other was preparing the election. This usually works.

[imjulier]

I've used "the taxpayer intended to be an S corp but did not understand the requirements for filing. Therefore, the request is being made now."

[Richcpaman]

The tax payer checked the box Marked "SCorp" on the SS-4 and thought that was all he had to do...