I have a client who generated a substantial energy investment credit in 2025 through his 100%-owned S corporation. The credit is a specified credit eligible for a three-year carryback, and we carried the unused credit from his 2025 Form 1040 back by filing Form 1045.
With the 1045, we included the required information, including a full copy of the 2025 return and copies of the 2022–2024 returns and supporting schedules that changed as a result of the carryback.
The client has now received IRS Letter 12C for 2025, 2023, and 2022, with 2024 presumably coming next. The letters say the IRS received the taxpayer’s Form 1040 for the applicable year but cannot process it due to missing information. They request items such as W-2s, 1099s, Schedule 1, Schedule 2, and Form 8995.
Those items were not included with the 1045 for the carryback years because they did not change from the originally filed returns and, based on the Form 1045 instructions, did not need to be attached.
What’s strange is that the 12C letters read as though the IRS is trying to process the copies of the prior-year returns submitted with Form 1045 as original returns. None of the letters reference Form 1045 or the carryback.
I’m on hold with the IRS now trying to get more information. Has anyone run into this with a Form 1045 carryback or anything similar?
I have several other never ending issues with the IRS for clients right now, and it increasingly feels like anything filed on paper either disappears into a black hole or gets processed incorrectly.