What does IRC 7502 actually say, and what does it protect?

IRC 7502(a) provides that if a document required to be filed with the IRS is postmarked on or before the last date prescribed for filing, the postmark date is treated as the filing date -- even if the document is received after that date. The rule applies to returns, claims for refund or credit, statements, elections, petitions (including Tax Court petitions), and any other document required or permitted to be filed with the IRS by a specific deadline. The document must actually be delivered: if the mailing is lost, the taxpayer generally cannot rely on IRC 7502 unless registered mail or an approved private delivery service was used and a receipt exists. IRC 7502 is a one-way safety valve: it saves timely-mailed documents received late, but it does not allow a document mailed after the deadline to be treated as timely. Verify current statutory text and IRS administrative guidance at IRS.gov.

What types of documents does IRC 7502 cover?

IRC 7502(a)(1) covers any return, claim, statement, or other document required or permitted to be filed with the Secretary of the Treasury. This includes: individual income tax returns (Form 1040 series), corporate income tax returns (Form 1120 series), partnership returns (Form 1065), estate and gift tax returns (Forms 706 and 709), information returns (Form 1099, W-2, 1065), claims for refund (Form 1040-X, 843), Tax Court petitions (filed with the Tax Court clerk), CDP election requests (Form 12153), OIC applications (Form 656), and elections or statements required by statute or regulation to be filed by a specific date. The rule is broad: if the code or regulations impose a filing deadline, IRC 7502 applies to that deadline -- including new filing obligations and elections created by legislation such as OBBBA 2025. Confirm whether a specific election or filing is covered by reviewing the applicable statute or regulation, and verify at IRS.gov.

What is the difference between certified mail and registered mail under IRC 7502?

Both certified mail and registered mail qualify for the evidentiary presumption under IRC 7502(c)(1), but they provide different levels of protection. Certified mail provides a mailing receipt stamped by the postal clerk with the date of acceptance, which creates a rebuttable presumption that the document was timely mailed on the date shown. Registered mail provides all of the same protections, plus: the piece is registered into the USPS system at the point of acceptance, assigned a unique registration number, handled under tighter security protocols, and tracked at each transfer point. Registered mail provides stronger evidentiary support in a dispute because the IRS cannot credibly argue the piece was not accepted on the date shown on the registry receipt. For high-stakes filings (Tax Court petitions, claims for refund near the deadline, CDP election requests), registered mail is the stronger choice. Certified mail is acceptable and widely used for routine filings. Either service generates the receipt the practitioner must retain. Verify current USPS service descriptions and IRC 7502(c)(1) requirements at IRS.gov.

Which private delivery services are approved under IRC 7502(f) and Notice 2023-36?

IRC 7502(f) authorizes the IRS to designate private delivery services (PDS) whose delivery records receive the same treatment as a USPS postmark. The current controlling notice for approved PDS designations is Notice 2023-36, which supersedes Rev. Proc. 2011-58 and all prior guidance. Notice 2023-36 designates specific named services from DHL Express, FedEx, and UPS -- but only specific service tiers within each carrier, not all services offered by those carriers. For example, a FedEx standard ground delivery is NOT on the approved list even though FedEx Express Priority Overnight IS. Similarly, not all UPS services qualify: UPS Next Day Air and UPS Next Day Air Saver are designated, but slower UPS ground services are not. The specific list of approved service names changes as carriers update their offerings. Practitioners must verify the current list of designated services by consulting Notice 2023-36 directly (available at IRS.gov) and confirming that the specific named service they intend to use appears in the notice. Do not rely on the carrier name alone -- the service tier controls. Verify the current approved PDS list at IRS.gov before each filing.

What happens if a practitioner uses a non-approved private delivery service?

If a document is sent via a PDS that is not on the IRS-approved list under IRC 7502(f) and Notice 2023-36, the delivery record from that PDS does NOT count as a timely postmark for purposes of IRC 7502. The document is treated as filed on the date it is physically received by the IRS -- not the date it was tendered to the carrier. If the IRS receives it after the deadline, the document is treated as late, regardless of when it was deposited with the carrier. This is one of the most common and costly practitioner errors in federal tax procedure. Practitioners have lost Tax Court petitions (a jurisdictional failure), refund claims, and CDP elections by using non-designated PDS services. The IRS has no discretion to treat a non-approved PDS delivery record as a postmark, and courts have applied this rule strictly. Always use USPS certified or registered mail, or a specifically named IRS-designated PDS service verified against Notice 2023-36 at IRS.gov, for every deadline-sensitive filing.

Does a postage-meter date count as a postmark under IRC 7502?

Not automatically. The postmark that IRC 7502(a) refers to is a USPS postmark -- the cancellation mark applied by the post office at the time of acceptance. A postage meter date is printed by the sender's machine and does not necessarily reflect when the piece was accepted into the USPS system. If a metered piece is deposited in a USPS collection box or handed to a postal carrier and is physically accepted and postmarked by USPS on the same date as the meter date, the USPS postmark controls. The problem arises when a metered piece is deposited late in the day and is not physically postmarked (cancelled) by USPS until the following day. In that case, the USPS postmark date -- the day after the meter date -- is what controls under IRC 7502, and if that is one day after the deadline, the filing is late. The Surowka line of cases addressed this issue, and courts have declined to treat a private meter date as a substitute for a USPS postmark. To protect against this risk: always obtain a window-service acceptance stamp from a USPS clerk when the piece is physically tendered, or use certified or registered mail, which generates a dated acceptance receipt at the point of mailing.

Does IRC 7502 apply to electronically filed returns?

No. IRC 7502 applies only to documents filed via physical mail or approved private delivery service. Electronically filed returns, extensions, and other e-filed documents receive a separate electronic postmark issued by the IRS e-file system (or by the transmission intermediary) at the time the transmission is accepted. The e-file rules -- not IRC 7502 -- govern the timeliness of electronic submissions. An e-filed return that is accepted by the IRS e-file system before midnight on the due date is treated as filed on that date, regardless of when it is processed. Practitioners should confirm that an e-file submission has been accepted (not merely transmitted) before treating it as timely filed. A rejected e-file transmission is not filed until the error is corrected and the return is re-transmitted and accepted. If an e-file is rejected close to a deadline, assess whether a paper filing by midnight on the due date is feasible, and confirm at IRS.gov which returns may be paper-filed after e-file rejection without penalty.

How does IRC 7502 apply to Tax Court petitions?

IRC 7502 applies to Tax Court petitions, and this is one of the highest-stakes applications of the statute because the Tax Court's jurisdiction over a petition depends entirely on whether it was timely filed. Under IRC 6213(a), a taxpayer has 90 days (or 150 days if the notice was addressed to a person outside the United States) from the mailing of a statutory Notice of Deficiency (the 90-day letter) to file a petition with the Tax Court. This 90-day period is jurisdictional: if the petition is filed even one day late, the Tax Court lacks subject matter jurisdiction and must dismiss the case. Under IRC 7502, a petition mailed on or before the 90th day -- with a USPS postmark or designated PDS delivery record dated on or before that date -- is treated as timely filed even if it is received by the Tax Court clerk after the 90-day period. Tax Court Rule 22 codifies this rule. The critical practitioner error is using a non-approved PDS service: if the delivery record from a non-designated carrier shows the petition was tendered before the deadline but the Tax Court did not physically receive it until after the deadline, the Tax Court has no jurisdiction. Always use USPS certified or registered mail, or a specifically designated PDS service listed in Notice 2023-36, for Tax Court petitions. Verify current Tax Court filing procedures at ustaxcourt.gov and confirm the current PDS list at IRS.gov.

What is the last-known-address rule and how does it interact with IRC 7502?

The last-known-address rule governs IRS notices sent to taxpayers: under IRC 6212, a Notice of Deficiency is valid if sent to the taxpayer's last known address, even if the taxpayer does not actually receive it. This interacts with IRC 7502 in the following way: if the IRS sends a 90-day letter to the taxpayer's last known address and the taxpayer does not receive it (because they have moved and not notified the IRS), the 90-day petition period begins running on the date the notice is mailed to the last known address. The taxpayer bears the burden of keeping the IRS informed of their current address (typically by filing a current-year return or submitting Form 8822). If the taxpayer misses the 90-day window because they did not receive the notice at an outdated address, the Tax Court may still lack jurisdiction over a late petition. In this situation, practitioners should analyze whether the notice was properly mailed to the correct last known address and whether there are grounds to challenge notice validity before conceding jurisdiction. Separately, for mailing documents TO the IRS, the practitioner should always use the correct IRS address for the specific document type, because IRC 7502 requires the piece to be properly addressed -- a piece mailed to the wrong IRS address may not receive the same treatment as one timely mailed to the correct address. Verify current IRS mailing addresses by document type at IRS.gov.

Does IRC 7502 apply to CDP election requests filed with the IRS?

Yes. A CDP election request (Form 12153) must be filed within 30 days of the date of the Final Notice of Intent to Levy (Notice 1058 or LT11) or within 30 days of the date of the Notice of Federal Tax Lien (Letter 3172) for an equivalent hearing. Because IRC 7502 applies to any document required or permitted to be filed with the Secretary of the Treasury, the timely-mailed rule governs the timeliness of CDP election requests. If Form 12153 is postmarked (via USPS or a designated PDS under Notice 2023-36) on or before the 30th day, it is treated as timely filed even if received by the IRS after the deadline. The 30-day CDP window is critical: losing it forfeits the taxpayer's right to a Collection Due Process hearing and the right to Tax Court review of an adverse determination. Because CDP rights are this valuable, practitioners should file Form 12153 in person at an IRS office (obtaining a date-stamped receipt) or via USPS certified or registered mail, retaining the mailing receipt, and logging the mailing date immediately. Verify current CDP notice procedures and deadlines at IRS.gov.

What is the evidentiary presumption for certified and registered mail under IRC 7502(c)(1)?

Under IRC 7502(c)(1), if a document is sent via certified or registered mail and the sender can produce the mailing receipt (PS Form 3800 for certified, or the registration receipt for registered), the date on the receipt is treated as a rebuttable presumption of the postmark date. This means the IRS bears the burden of proving the document was NOT mailed on the date shown -- a much easier evidentiary position for the taxpayer than the common-law mailbox rule, which requires the taxpayer to prove delivery. Without certified or registered mail (or a designated PDS service with a compliant delivery record), the taxpayer must prove actual delivery by a preponderance of the evidence. If the IRS has no record of receiving the document, a taxpayer relying on ordinary first-class mail has no statutory evidentiary presumption and must rely on extrinsic evidence (witness testimony, copies, circumstantial evidence) to prove the document was timely mailed and received. Given the stakes -- late filing penalties, forfeiture of Tax Court jurisdiction, loss of refund claims -- there is no sound reason to use ordinary first-class mail for any deadline-sensitive federal tax document. Verify current certified and registered mail requirements at usps.com and in Treas. Reg. 301.7502-1.

What penalties apply if IRC 7502 does not save a late-filed return?

If IRC 7502 does not apply -- because the document was not timely postmarked, the wrong mailing service was used, or the piece was lost -- the document is treated as filed on the date it is physically received by the IRS. If that date is after the due date (including any validly requested extension), the following penalty regime applies: (1) under IRC 6651(a)(1), a failure-to-file penalty of 5% of the unpaid tax per month (or fraction of a month), up to 25% of the unpaid tax, with a minimum penalty for returns more than 60 days late; (2) under IRC 6651(a)(2), a failure-to-pay penalty of 0.5% of the unpaid tax per month, up to 25% of the unpaid tax; (3) interest under IRC 6601 accruing from the original due date. For refund claims, a late filing means the claim falls outside the IRC 6511 lookback window and the refund may be barred entirely. For Tax Court petitions, lateness means the Tax Court lacks jurisdiction and the IRS can assess the full deficiency without court review. Practitioners should assess whether a reasonable cause defense under IRC 6651(c) is available, but prevention through proper mailing protocol is always preferable to a penalty abatement argument. Verify current penalty rates and reasonable cause standards at IRS.gov.

How does the OBBBA 2025 interact with IRC 7502?

The One Big Beautiful Bill Act (OBBBA) 2025 created new filing obligations, elections, and forms with specific statutory deadlines. Where these new obligations require a physical document to be filed with the IRS or another specified recipient by a date certain, IRC 7502 governs the timeliness of that filing. Practitioners handling OBBBA-related filings -- including new elections and forms arising from OBBBA's modifications to bonus depreciation, small business provisions, and other areas -- should apply the same mailing protocol used for any other deadline-sensitive federal tax document: certified or registered mail with a dated receipt, or an IRS-designated PDS service listed in Notice 2023-36. Because OBBBA created new filings with new deadlines in 2025 and 2026, there is limited administrative guidance on which of these new filings are subject to IRC 7502, and the e-file availability for some new forms may still be limited. Confirm whether a specific OBBBA-related filing must be paper-filed and whether IRC 7502 applies by reviewing the applicable OBBBA statutory provision and any IRS guidance at IRS.gov. When in doubt, use certified or registered mail.

What is the role of third-party mailing agents in an IRC 7502 analysis?

Some practitioners and large-volume filers use third-party mailing and document processing services (filing agents, process servers, or courier services) to handle physical submissions to the IRS. For IRC 7502 to apply, the postmark must be a USPS postmark (from the USPS cancellation) or a designated PDS delivery record under Notice 2023-36. The identity of the mailing agent is not relevant to the analysis: what matters is the date on the USPS postmark or designated PDS record, and whether the piece was accepted into the qualifying mail or delivery system on or before the filing deadline. If a third-party agent tenders the document to USPS or a designated PDS on the due date, and a dated acceptance receipt is issued, IRC 7502 applies. If the agent uses its own courier system (not USPS and not a designated PDS), the delivery record from that courier is not a qualifying postmark under IRC 7502. Practitioners should confirm, in writing, with any third-party mailing agent which delivery method will be used for each filing, and obtain and retain all dated mailing receipts. Verify current third-party mailing procedures and IRC 7502 requirements at IRS.gov and in Treas. Reg. 301.7502-1.

What should a practitioner do if a client's mailing receipt has been lost?

If the mailing receipt for a certified or registered mail item has been lost, the practitioner has two secondary options: (1) USPS can provide verification of an article's mailing and postmark date through its tracking systems for certified mail (using the article number from the green card or the online tracking record); and (2) USPS business mail service records, internal mail logs, and contemporaneous notes from the practitioner's office can serve as extrinsic evidence of the mailing date, though these are weaker than the original receipt. For registered mail, USPS maintains detailed records at each transfer point; a formal request to USPS can retrieve delivery history. Without any receipt or corroborating evidence, the practitioner must rely on the common-law mailbox rule, which requires proving by a preponderance of the evidence that the document was deposited in the mail in properly addressed, stamped form. This is a difficult evidentiary burden when the IRS claims non-receipt. Prevention is the only reliable solution: retain mailing receipts indefinitely for every deadline-sensitive tax filing and maintain an office log recording the mailing date, recipient, article type, article number, and the filing it corresponds to.

Does IRC 7502 apply to documents sent to the Tax Court or only to the IRS?

IRC 7502 applies to any document required or permitted to be filed under the Internal Revenue Code, and by its terms covers Tax Court petitions because filing a petition with the Tax Court is a procedure under the Code (IRC 6213(a)). The statute uses the phrase 'filed with the Secretary' but regulatory guidance and case law confirm that IRC 7502 extends to Tax Court petitions filed with the Tax Court clerk. Tax Court Rule 22 specifically adopts the IRC 7502 framework for petitions filed by mail or designated PDS. A petition postmarked (USPS) or stamped (designated PDS under Notice 2023-36) on or before the 90th day from the NOD mailing date is treated as timely filed with the Tax Court, even if physically received after the 90-day period. Note that the Tax Court has its own clerk's office and its own address: petitions must be addressed to the United States Tax Court in Washington, D.C., not to the IRS. A petition mailed to the wrong address -- even if postmarked timely -- may create delivery complications that the practitioner will have to address. Always confirm the correct Tax Court mailing address at ustaxcourt.gov before filing, and retain proof of mailing.

IRC 7502 Timely Mailed Timely Filed Postmark Rule

1. Overview: What IRC 7502 Does and Why It Matters

IRC 7502 establishes the "mailbox rule" for federal tax filings: a document is deemed filed on the date of the U.S. postmark, or the date recorded by an IRS-approved private delivery service (PDS), provided the document is deposited in the mail or delivery system on or before the filing deadline and is properly addressed. The core purpose of the rule is to protect taxpayers from lateness caused by postal delay after a timely mailing -- the risk shifts from the sender to the postal system once the document is in the mail.

The rule applies broadly: returns, claims for refund, elections, statements, and Tax Court petitions all fall within its scope. It does not apply to electronically filed documents, which are governed by a separate e-file postmark system. And it has significant technical requirements that practitioners violate at their clients' peril: most notably, the requirement that any private delivery service used must be one specifically designated by the IRS in Notice 2023-36 (the current controlling notice), and the requirement that metered mail is not equivalent to a USPS postmark unless the piece is physically accepted and postmarked by USPS on the same date.

This guide covers the mechanics of IRC 7502, the evidentiary advantages of certified and registered mail, the approved PDS list trap under Notice 2023-36, the postage-meter question, the e-file exclusion, Tax Court petition timing, OBBBA 2025 implications, and a 7-step practitioner mailing protocol designed to ensure the mailbox rule is available for every high-stakes federal tax deadline.

2. IRC 7502(a): The Timely-Mailed Equals Timely-Filed Rule

IRC 7502(a)(1) provides: if a document required or permitted to be filed with the Secretary of the Treasury is delivered after the prescribed deadline, the document is treated as filed on the date of the postmark stamped on the cover, provided (1) the document is deposited in the mail in the United States in an envelope or other appropriate wrapper, properly addressed to the agency, officer, or office with which the document is required to be filed, before the last date prescribed for filing, and (2) the postmark date falls on or before that last date.

Several terms in this provision have specific meanings that matter in practice:

Postmark: Refers to the U.S. Postal Service cancellation stamp applied at the time of acceptance, or the equivalent stamped delivery record from a designated private delivery service under IRC 7502(f).
Properly addressed: The document must be addressed to the correct IRS office, Tax Court, or other recipient for the specific document type. A piece addressed to the wrong location does not qualify for the IRC 7502 protection, even if postmarked timely.
Deposited in the mail in the United States: The piece must enter the USPS system (or a designated PDS system) within the United States on or before the deadline, not merely be given to a courier or deposited in an unofficial collection point.
Before the last date prescribed for filing: If the postmark date falls on the deadline date itself, the rule is satisfied. If the postmark date is one day after the deadline, the rule is not satisfied and the document is late.

Scope: What Documents Are Covered

IRC 7502(a) covers returns, claims for refund or credit, statements, elections, and petitions -- essentially any document the Internal Revenue Code or regulations require or permit to be filed with the Secretary of the Treasury or with the Tax Court. This includes:

Individual income tax returns (Form 1040 series) and corporate, partnership, estate, and gift tax returns
Amended returns and claims for refund (Form 1040-X, Form 843)
Tax Court petitions filed within the 90-day (or 150-day foreign) period after a Notice of Deficiency
CDP election requests (Form 12153) filed within the 30-day window
OIC applications (Form 656) and installment agreement requests
Elections required under the Code to be made by a specific date (including S corporation elections, basis elections, and various treaty elections)
New filing obligations created by OBBBA 2025 where the statute imposes a deadline and requires physical filing

One important exclusion: documents required to be filed directly with a court other than the Tax Court (for example, a complaint in a refund suit in the U.S. District Court or Court of Federal Claims) are not governed by IRC 7502. Those courts have their own filing deadline rules. Verify the applicable deadline and filing mechanics for any specific document type at IRS.gov or with the relevant court.

3. Certified vs. Registered Mail: The Evidentiary Presumption Under IRC 7502(c)(1)

IRC 7502(c)(1) provides that if a document is sent by registered or certified mail, the registration or certification is treated as prima facie evidence that the document was delivered to the agency or officer to which it was addressed. This statutory presumption shifts the evidentiary burden to the IRS: once a practitioner produces the postmarked mailing receipt from certified or registered mail, the IRS must prove the document was not mailed on the date shown.

This is a significant evidentiary advantage over ordinary first-class mail. Without certified or registered mail, the taxpayer must rely on the common-law mailbox rule and prove by a preponderance of the evidence that the document was properly mailed and received. If the IRS has no record of receiving the document, this is an extremely difficult burden to meet. With a certified mail receipt showing the postmark date, the burden shifts entirely.

Registered vs. Certified Mail: Know the Difference

Both qualify for the IRC 7502(c)(1) evidentiary presumption, but they are not identical. Certified mail (PS Form 3800) is the standard choice for routine practitioner filings: it is inexpensive, generates a dated acceptance receipt, and provides delivery tracking. Registered mail provides a higher level of security: the piece is sealed, registered into the USPS system at the point of acceptance with a unique number, tracked at every transfer point, and handled under stricter custody protocols. For the highest-stakes filings -- Tax Court petitions, large refund claims near the 6511 deadline, CDP election requests -- registered mail provides the stronger evidentiary record and is harder for the IRS to challenge. Use certified mail for routine filings; consider registered mail for any filing where the consequences of losing the delivery record would be catastrophic. Always retain the original receipt.

What Happens Without Certified or Registered Mail

Ordinary first-class mail carries no IRC 7502(c)(1) presumption. If the IRS denies receipt and the practitioner cannot produce a postmarked receipt or delivery confirmation, the filing will be treated as filed on the date the IRS physically receives it (if it receives it at all). Given the cost of first-class mail versus certified mail for individual mailings -- a difference of a few dollars -- there is no sound reason to use ordinary first-class mail for any document with a statutory deadline. Establish an office policy: every deadline-sensitive federal tax document goes out certified mail at minimum, with the receipt retained and logged.

4. Approved Private Delivery Services Under IRC 7502(f) and Notice 2023-36

IRC 7502(f) authorizes the IRS to designate private delivery services whose delivery records receive the same treatment as a USPS postmark. The current controlling notice is IRS Notice 2023-36, which supersedes Rev. Proc. 2011-58 and all prior PDS guidance. Notice 2023-36 designates specific named service tiers from DHL Express, FedEx, and UPS -- but only specific services within each carrier, not the carrier's entire service catalog.

High-Stakes Trap: Not All FedEx, UPS, or DHL Services Are Approved

This is one of the most consequential and most common practitioner errors in federal tax procedure. Many practitioners assume that using any FedEx, UPS, or DHL service qualifies for the IRC 7502 mailbox rule -- it does not. Only specifically named service tiers from those carriers that appear in Notice 2023-36 qualify. FedEx ground delivery, UPS ground delivery, and non-express DHL services are NOT on the approved list. Using a non-approved service means the delivery record from that carrier has no effect under IRC 7502: the document is treated as filed on the date it is physically received by the IRS, not the date it was tendered to the carrier. Tax Court petitions, CDP elections, and refund claims have been lost because a practitioner used a non-designated service. Always verify the specific service name against the current approved list in Notice 2023-36 at IRS.gov before each filing. Do not rely on the carrier's name -- the service tier controls.

Approved Private Delivery Services: Reference Table

The table below reflects the IRS-designated services under Notice 2023-36 as of the date of this guide. The IRS may update or revise the approved list in future guidance. Practitioners must verify the current approved list directly by consulting Notice 2023-36 and any subsequent IRS guidance at IRS.gov before each filing. Do not treat this table as a substitute for that verification.

Service Name	Carrier / Provider	Approval Status (Notice 2023-36)	Practitioner Notes
DHL Express 9:00	DHL Express	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
DHL Express 10:30	DHL Express	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
DHL Express 12:00	DHL Express	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
DHL Express Worldwide	DHL Express	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
DHL Ground / DHL Standard	DHL	Not Designated	Non-express DHL services are not on the approved list. Using these services forfeits the IRC 7502 protection.
FedEx First Overnight	FedEx	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
FedEx Priority Overnight	FedEx	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
FedEx Standard Overnight	FedEx	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
FedEx 2Day / FedEx 2Day A.M.	FedEx	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
FedEx Ground / FedEx Home Delivery	FedEx	Not Designated	FedEx ground services are not on the approved list. A very common practitioner error. Using these services forfeits the IRC 7502 protection.
UPS Next Day Air / UPS Next Day Air Saver	UPS	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
UPS 2nd Day Air / UPS 2nd Day Air A.M.	UPS	Designated	Verify current service name at IRS.gov; confirm the named service appears in Notice 2023-36.
UPS Ground / UPS Standard	UPS	Not Designated	UPS ground services are not on the approved list. Using these services forfeits the IRC 7502 protection.

Important verification note: The IRS may add, remove, or rename designated services in future guidance. Notice 2023-36 is the current controlling authority as of the date of this guide, but the IRS has historically issued updated PDS designation notices over time. Always verify the current approved list directly in the current IRS notice at IRS.gov before tendering any deadline-sensitive document to a private delivery service. Do not rely on memory, firm policy, or this guide as a substitute for checking the current notice.

How to Preserve the PDS Record Under IRC 7502(f)

When using a designated PDS, the delivery record that triggers IRC 7502 protection is the "timely filing record" issued by the carrier at the time the piece is accepted -- not the delivery confirmation. Retain the pickup or dropoff receipt showing the date the piece was tendered to the carrier, not just the electronic tracking confirmation showing delivery. Log the tracking number, the date, the service name, the recipient address, and the document it corresponds to. In any future dispute, the IRS may request evidence of the specific service used and the acceptance date.

5. Metered Mail and the Postage-Meter Trap

A postage meter prints a date on the envelope at the time the meter is applied -- this date is set by the sender's machine, not by the USPS. It is not a USPS postmark. This distinction matters significantly under IRC 7502.

The USPS postmark is the cancellation stamp applied by a USPS employee or machine at the post office counter or processing facility at the time the piece is accepted into the USPS system. If a metered piece is handed over the counter to a USPS clerk on the due date and the clerk applies a USPS cancellation on the same date, the USPS postmark date controls -- and IRC 7502 is satisfied if that date falls on or before the deadline.

The problem arises in the following common scenarios:

A metered piece is placed in an outgoing mail tray or USPS collection box at the end of the day on the deadline, and is not physically processed (cancelled) by USPS until the following day. In that situation, the USPS postmark date is the day after the deadline -- one day late.
A metered piece is dropped in a commercial outgoing mail system (not a USPS collection box or handed to a USPS clerk) and processed internally by a mailroom before being handed to USPS. If USPS does not accept and postmark the piece until after the deadline, IRC 7502 is not satisfied.
A piece metered with today's date is not actually deposited in the USPS system until the next day. Again, the USPS postmark controls.

Critical: A Postage-Meter Date Is Not a USPS Postmark

Courts have consistently held that a postage-meter date does not constitute a "postmark" within the meaning of IRC 7502 unless the piece was also physically stamped (cancelled) by USPS on that same date. The Surowka line of cases and related Tax Court decisions have addressed this rule. The safest practice is to never rely on a postage meter for any filing subject to a statutory deadline. Instead, take the document to a USPS retail counter, hand it over to a USPS clerk, and obtain a window-service acceptance stamp directly on the document or on the accompanying certified or registered mail receipt. That clerk-applied stamp is a USPS postmark and is the cleanest possible evidence under IRC 7502. If the office uses a metering machine, treat any deadline-sensitive mailing as if it needs a separate USPS counter visit for the acceptance stamp. Verify current USPS postmark rules and IRS administrative guidance on metered mail at IRS.gov and usps.com.

6. The E-File Exclusion: IRC 7502 Does Not Apply to Electronic Filings

IRC 7502 applies only to documents filed by physical mail or by a designated private delivery service. It does not apply to electronically filed returns, extensions, elections, or other documents transmitted through the IRS e-file system.

Electronically filed documents have their own timeliness framework. When a return or other document is transmitted through an Authorized IRS e-file Provider (or directly by the taxpayer through IRS Free File or other e-file channels), the IRS e-file system issues an electronic acknowledgment at the time of acceptance. The date and time on that electronic acknowledgment is treated as the filing date for timeliness purposes -- it operates as an electronic postmark, but the rules are distinct from IRC 7502.

E-File Reminder: Acceptance Is Not the Same as Transmission

An e-file submission is only timely if it is accepted by the IRS system before the deadline -- not merely transmitted. If a return is transmitted on the due date but rejected (because of an error in the SSN, the EIN, the prior-year AGI PIN, or any other field that causes the IRS to reject the submission), the return is not filed. The practitioner must correct the error and retransmit, and the new acceptance date governs. If a rejection is discovered on the deadline date with insufficient time to correct and retransmit, the practitioner must assess whether a paper filing by midnight on the due date is feasible, taking into account IRC 7502's requirements for that paper filing. Always confirm e-file acceptance status before treating a transmission as a timely filing, and retain the IRS acknowledgment record. Verify current e-file rules, rejection procedures, and grace period guidance at IRS.gov.

Certain document types do not yet have e-file options. For elections, statements, or forms that must be filed on paper (including some elections created by OBBBA 2025 whose e-file availability may still be limited), IRC 7502's requirements apply in full. When in doubt, confirm at IRS.gov whether a specific document type may be e-filed and whether the e-file option is currently available for the applicable tax year.

7. Tax Court Petition Timing: A Jurisdictional Application of IRC 7502

No application of IRC 7502 carries higher stakes than its use for Tax Court petitions. The right to petition the Tax Court depends entirely on timely filing, and the Tax Court's jurisdiction is jurisdictional in the strict sense: it cannot be waived, cannot be conferred by consent, and cannot be remedied after the fact. If a Tax Court petition is filed even one day after the 90-day (or 150-day) period, the Tax Court must dismiss the case for lack of jurisdiction, and the IRS can proceed to assess the full deficiency shown in the Notice of Deficiency.

Tax Court Petition Timing Is Jurisdictional: There Is No Equitable Exception

Unlike many procedural deadlines in tax law, the 90-day Tax Court petition period under IRC 6213(a) is jurisdictional. Courts have repeatedly held that equitable tolling, reasonable cause, or other exceptions do not apply to extend this deadline. If the petition is late by even one day -- for any reason -- the Tax Court has no jurisdiction. IRC 7502 is the only statutory mechanism that can save a late-delivered petition, and it requires that the petition was postmarked (USPS) or recorded by a designated PDS (Notice 2023-36) on or before the 90th day. A non-designated PDS delivery record does not save the petition. A postage-meter date without a USPS cancellation on the same date does not save the petition. Practitioners handling Tax Court petitions should use USPS certified or registered mail, hand the petition over the counter on the 90th day (or earlier), and retain the dated acceptance receipt. Verify current Tax Court petition procedures, the correct mailing address for the Tax Court, and the applicable deadline at ustaxcourt.gov.

Computing the 90-Day Period

The 90-day period begins on the day the IRS mails the Notice of Deficiency (the "90-day letter," also called the statutory notice of deficiency or SNOD). The count begins on the day after the mailing date of the NOD. The 90th day is the last day on which the petition may be postmarked. If the 90th day falls on a Saturday, Sunday, or federal legal holiday, IRC 7503 extends the deadline to the next business day.

For taxpayers whose notices were addressed to addresses outside the United States, the period is 150 days from the mailing date of the NOD. Determine whether the 90-day or 150-day rule applies based on the address on the NOD, not the taxpayer's current residence.

Related reading: our guide to IRC 6212 and 6213: Notice of Deficiency, 90-Day Letter, and Tax Court Jurisdiction covers the mechanics of the NOD and the 90-day petition right in full detail.

Tax Court Rule 22 and the Mailbox Rule

Tax Court Rule 22 codifies the IRC 7502 framework for petitions filed by mail or designated PDS. A petition is timely if the postmark (USPS) or the designated PDS delivery record (under Notice 2023-36) is dated on or before the last day to file, even if the Tax Court clerk does not receive the petition until after that date. The Tax Court clerk's office does not apply the common-law mailbox rule independently of IRC 7502: the statute controls. Petitions filed electronically through the Tax Court's electronic filing system (eFiling) receive a filing date based on the electronic system's acceptance timestamp.

8. OBBBA 2025 New Filing Obligations and IRC 7502

The One Big Beautiful Bill Act (OBBBA) 2025 created new filing obligations, elections, and forms across multiple areas of the Code. Where these obligations require a physical document to be submitted to the IRS by a specific date, IRC 7502 governs the timeliness of that submission.

Several OBBBA provisions are particularly relevant to the IRC 7502 analysis:

New elections and statements: OBBBA created or modified several elections that may be required to be filed on paper with the taxpayer's return or on a separately filed statement by a specific date. These are governed by IRC 7502 to the same extent as any other statutory election.
Modified bonus depreciation provisions: Elections related to OBBBA's bonus depreciation changes may require timely filing. Confirm whether each election may be e-filed with the return or must be paper-filed separately.
Small business and pass-through provisions: Various OBBBA provisions affecting S corporations, partnerships, and small business owners created new reporting obligations that may have paper-filing components subject to IRC 7502.

Because OBBBA was enacted in 2025 and implementing guidance continues to be issued, e-file availability for some new forms and elections remains limited. When in doubt, confirm at IRS.gov whether the specific OBBBA-related obligation may be electronically filed and whether IRC 7502 applies to the paper-filing alternative.

9. Penalties and Remedies When IRC 7502 Does Not Apply

When the mailbox rule does not protect a filing, the document is treated as filed on the date the IRS physically receives it. The consequences depend on the type of document and how late the physical receipt is.

Failure-to-File Penalty: IRC 6651(a)(1)

For income tax returns and most other returns subject to a filing deadline, a filing that is physically received by the IRS after the due date (including extensions) is subject to the IRC 6651(a)(1) failure-to-file penalty of 5% of the unpaid tax per month (or fraction of a month), up to a maximum of 25% of the unpaid tax. If the return is more than 60 days late, a minimum penalty applies -- the lesser of $510 (as adjusted) or 100% of the unpaid tax on the return. Interest under IRC 6601 accrues from the original due date on any unpaid tax.

A penalty under IRC 6651(a)(1) may be excused if the taxpayer demonstrates reasonable cause and the absence of willful neglect. A well-documented mailing protocol (showing that the document was in fact mailed, but the mailing service used was non-designated or the receipt was lost) may support a reasonable cause argument in appropriate cases. Consult our guide on IRC 6651: Failure to File, Failure to Pay, Reasonable Cause, and First-Time Abatement for a full analysis of the penalty and available defenses.

Refund Claim Deadline: IRC 6511

Claims for refund are subject to the IRC 6511 lookback periods: generally, the later of three years from the date the return was filed or two years from the date the tax was paid. If a refund claim is postmarked on or before the IRC 6511 deadline and the claim arrives late, IRC 7502 can save the claim if the mailing was timely and compliant. If the mailing was not IRC 7502-compliant and the physical receipt date falls outside the lookback period, the claim is barred and no refund can be issued, regardless of its merit. Consult our guide on IRC 6511: Claim for Refund, Limitation Periods, and the Informal Claim Doctrine for the full refund claim analysis.

Statute of Limitations Tolling: IRC 6503

Some IRC 7502 issues arise in the context of whether a filing or claim was timely enough to toll the assessment statute under IRC 6501 or the collection statute under IRC 6502. Our guide on IRC 6503: Statute of Limitations Tolling, Suspension, and the Collection CSED covers the tolling rules in full.

Collection Due Process Rights

If a CDP election request (Form 12153) is not timely filed under IRC 7502, the taxpayer loses the right to a CDP hearing and the right to Tax Court review of the IRS's collection action. An untimely CDP request may still be processed as an equivalent hearing, but equivalent hearings do not carry Tax Court review rights. Consult our guide on IRC 6330 and 6320: Collection Due Process, CDP, and CAP for the full CDP election analysis.

10. Practitioner Checklist: 7-Step Mailing Protocol to Preserve IRC 7502

The following 7-step protocol should be applied to every deadline-sensitive federal tax filing. Following this protocol consistently eliminates the most common IRC 7502 failure modes.

7-Step Mailing Protocol: Preserve IRC 7502 on Every Filing

Apply these steps to every return, claim, election, petition, or statutory filing subject to a federal tax deadline. Prevention is always more effective than a penalty abatement argument after the fact.

Use USPS certified or registered mail (preferred), or an IRS-designated PDS service confirmed against the current Notice 2023-36 list at IRS.gov. Never use ordinary first-class mail, non-designated PDS services, or metered mail without a separate USPS counter acceptance stamp for any filing with a statutory deadline.
Confirm the correct mailing address for the specific document type. Different document types go to different IRS offices, service centers, or addresses. For Tax Court petitions, use the current Tax Court mailing address at ustaxcourt.gov. An improperly addressed piece may not receive IRC 7502 protection.
Tender the document over the counter at a USPS retail location -- do not drop it in a collection box or an outgoing mail tray on the deadline date. Request a window-service acceptance stamp on the envelope or on the certified/registered mail receipt. Obtain the stamp directly from a USPS clerk.
Retain the original mailing receipt (PS Form 3800 for certified mail, or the registration receipt for registered mail, or the carrier's dated acceptance record for a designated PDS). Do not discard the receipt after the filing is confirmed received. Retain it indefinitely with the client file.
Log the mailing immediately: record the mailing date, document type, recipient (IRS office, Tax Court, or other), mailing service used, article number or tracking number, and the name of the staff member who performed the mailing.
Confirm delivery. For certified and registered mail, confirm delivery through the USPS tracking system. For a designated PDS, confirm delivery through the carrier's tracking system. Log the confirmed delivery date. If delivery is not confirmed within a reasonable period, contact the carrier and investigate.
If the document is not received by the intended recipient (IRS, Tax Court, or other), act immediately: contact the carrier, file a trace, obtain documentation of the mailing, and assess whether a duplicate must be filed. Do not wait. Missing a statutory deadline because the original was lost in transit without a dated receipt is a loss that cannot be recovered.

High-Stakes Filings: Elevated Protocol

For the highest-stakes filings -- Tax Court petitions (jurisdictional deadline), large refund claims near the IRC 6511 deadline, CDP election requests (30-day window), and new OBBBA elections -- consider the following additional steps:

Use registered mail rather than certified mail, for the stronger evidentiary presumption and more detailed USPS tracking record.
Hand-deliver the document to the Tax Court clerk's office or the IRS office in person if geography permits, and obtain a date-stamped receipt from the clerk. This eliminates all IRC 7502 uncertainty.
Mail the document at least five business days before the deadline, to provide a buffer against processing delays, address-verification issues, or office errors discovered at the last moment.
Confirm the recipient's current address before mailing. IRS and Tax Court mailing addresses can change. Always verify at IRS.gov or ustaxcourt.gov immediately before mailing.

11. Frequently Asked Questions: IRC 7502 Timely Mailed Timely Filed

What does IRC 7502 actually say, and what does it protect?

IRC 7502(a) provides that if a document required to be filed with the IRS is postmarked on or before the last date prescribed for filing, the postmark date is treated as the filing date -- even if the document is received after that date. The rule applies to returns, claims for refund or credit, statements, elections, petitions (including Tax Court petitions), and any other document required or permitted to be filed with the IRS by a specific deadline. The document must actually be delivered: if the mailing is lost, the taxpayer generally cannot rely on IRC 7502 unless registered mail or an approved private delivery service was used and a receipt exists. IRC 7502 is a one-way safety valve: it saves timely-mailed documents received late, but it does not allow a document mailed after the deadline to be treated as timely. Verify current statutory text and IRS administrative guidance at IRS.gov.
What types of documents does IRC 7502 cover?

IRC 7502(a)(1) covers any return, claim, statement, or other document required or permitted to be filed with the Secretary of the Treasury. This includes individual income tax returns, corporate income tax returns, partnership returns, estate and gift tax returns, information returns, claims for refund, Tax Court petitions, CDP election requests, OIC applications, and elections or statements required by statute or regulation to be filed by a specific date. The rule is broad: if the code or regulations impose a filing deadline, IRC 7502 applies to that deadline, including new filing obligations created by OBBBA 2025. Confirm whether a specific election or filing is covered by reviewing the applicable statute or regulation, and verify at IRS.gov.
What is the difference between certified mail and registered mail under IRC 7502?

Both certified mail and registered mail qualify for the evidentiary presumption under IRC 7502(c)(1), but they differ in the level of security and evidentiary strength. Certified mail provides a mailing receipt stamped by the postal clerk with the date of acceptance, creating a rebuttable presumption that the document was timely mailed. Registered mail provides all of the same protections and adds a higher level of security and tracking at every transfer point, providing the stronger evidentiary record for disputed high-stakes filings. For Tax Court petitions and large refund claims near the 6511 deadline, registered mail is the stronger choice. Either service generates a dated receipt that must be retained. Verify current USPS service descriptions and IRC 7502(c)(1) requirements at IRS.gov.
Which private delivery services are approved under IRC 7502(f) and Notice 2023-36?

The current controlling notice is Notice 2023-36, which supersedes Rev. Proc. 2011-58. It designates specific named service tiers from DHL Express, FedEx, and UPS, but only specific services within each carrier -- not the carrier's full service catalog. For example, FedEx Priority Overnight is designated; FedEx Ground is not. Always verify the specific service name against the current approved list in Notice 2023-36 at IRS.gov before each filing. The list may be updated in future guidance. Verify the current approved PDS list at IRS.gov before every deadline-sensitive filing.
What happens if a practitioner uses a non-approved private delivery service?

If a document is sent via a PDS that is not on the IRS-approved list under Notice 2023-36, the delivery record from that service has no effect under IRC 7502. The document is treated as filed on the date it is physically received by the IRS. If that is after the deadline, the filing is late. Tax Court petitions, refund claims, and CDP elections have been lost because a practitioner used a non-designated PDS. The IRS has no discretion to treat a non-approved PDS delivery record as a postmark. Always verify the specific service name against the current Notice 2023-36 list at IRS.gov before each filing.
Does a postage-meter date count as a postmark under IRC 7502?

Not automatically. A postage meter date printed by the sender's machine is not a USPS postmark unless the piece was also physically cancelled (postmarked) by USPS on that same date. If a metered piece is deposited in a collection box or outgoing mail tray and is not physically cancelled by USPS until the following day, the USPS cancellation date controls -- and if that date is after the deadline, the filing is late. Courts have declined to treat a private meter date as a substitute for a USPS postmark. The safest approach is to obtain a window-service acceptance stamp directly from a USPS clerk for any deadline-sensitive mailing. Verify current USPS postmark rules and IRS guidance at IRS.gov.
Does IRC 7502 apply to electronically filed returns?

No. IRC 7502 applies only to documents filed via physical mail or approved private delivery service. Electronically filed returns and other e-filed documents receive a separate electronic postmark issued by the IRS e-file system at the time the transmission is accepted. An e-file submission is only timely if it is accepted -- not merely transmitted -- before the deadline. A rejected e-file is not filed. If a rejection is discovered close to a deadline, assess whether a paper filing is feasible and apply IRC 7502's requirements to that paper filing. Verify current e-file rules and rejection procedures at IRS.gov.
How does IRC 7502 apply to Tax Court petitions?

IRC 7502 applies to Tax Court petitions, and this is one of the highest-stakes applications of the statute because the Tax Court's jurisdiction is jurisdictional: a late petition cannot be saved by equitable arguments. Under IRC 6213(a), the taxpayer has 90 days from the mailing of the Notice of Deficiency to file a petition. Under IRC 7502, a petition postmarked (USPS) or recorded by a designated PDS (Notice 2023-36) on or before the 90th day is timely, even if received by the Tax Court after that date. A non-designated PDS record does not save the petition. Always use USPS certified or registered mail for Tax Court petitions, and retain the dated acceptance receipt. Verify current Tax Court procedures at ustaxcourt.gov.
What is the last-known-address rule and how does it interact with IRC 7502?

The last-known-address rule under IRC 6212 governs IRS notices: a Notice of Deficiency is valid if sent to the taxpayer's last known address, even if the taxpayer does not receive it because they have moved without notifying the IRS. This means the 90-day petition period can begin running on the date the IRS mails the NOD to an outdated address. For documents sent TO the IRS, IRC 7502 requires that the piece be properly addressed to the correct IRS address for the specific document type. A piece mailed to the wrong IRS address may not receive IRC 7502 protection. Always verify the current correct IRS mailing address for each document type at IRS.gov before mailing.
Does IRC 7502 apply to CDP election requests filed with the IRS?

Yes. A CDP election request (Form 12153) must be filed within 30 days of the Final Notice of Intent to Levy or NFTL notice. IRC 7502 governs the timeliness of CDP election requests: a Form 12153 postmarked (USPS or designated PDS under Notice 2023-36) on or before the 30th day is treated as timely filed. Losing the 30-day CDP window forfeits the taxpayer's right to a Collection Due Process hearing and Tax Court review. File CDP election requests via USPS certified or registered mail and retain the mailing receipt. Verify current CDP notice procedures at IRS.gov.
What is the evidentiary presumption for certified and registered mail under IRC 7502(c)(1)?

Under IRC 7502(c)(1), if a document is sent via certified or registered mail and the sender produces the mailing receipt, the date on the receipt is treated as a rebuttable presumption of the postmark date. The IRS then bears the burden of proving the document was not mailed on the date shown -- a much easier evidentiary position for the taxpayer than ordinary first-class mail, which requires the taxpayer to prove delivery by a preponderance of the evidence. Without a certified or registered mail receipt, if the IRS claims non-receipt, the taxpayer must rely on extrinsic evidence, which is often insufficient. Verify current certified and registered mail requirements at usps.com and in Treas. Reg. 301.7502-1.
What penalties apply if IRC 7502 does not save a late-filed return?

If IRC 7502 does not apply and the IRS receives the document after the due date, the IRC 6651(a)(1) failure-to-file penalty applies: 5% of the unpaid tax per month, up to 25%, with a minimum penalty for returns more than 60 days late. A failure-to-pay penalty under IRC 6651(a)(2) and interest under IRC 6601 also accrue. For refund claims, a physically late receipt that falls outside the IRC 6511 lookback window bars the refund entirely. For Tax Court petitions, lateness eliminates the Tax Court's jurisdiction. Reasonable cause under IRC 6651(c) may excuse filing penalties in appropriate cases, but prevention through proper mailing protocol is always preferable. Verify current penalty rates and reasonable cause standards at IRS.gov.
How does the OBBBA 2025 interact with IRC 7502?

OBBBA 2025 created new filing obligations, elections, and forms with specific statutory deadlines. Where these obligations require a physical document to be submitted to the IRS by a date certain, IRC 7502 governs the timeliness of that submission. Because e-file availability for some new OBBBA forms and elections may still be limited, paper filings subject to IRC 7502 are common for new OBBBA-related items. Confirm whether each specific OBBBA-related filing must be paper-filed by reviewing the applicable statutory provision and current IRS guidance at IRS.gov. When paper filing is required, apply the full 7-step mailing protocol described in this guide.
What is the role of third-party mailing agents in an IRC 7502 analysis?

The identity of the mailing agent is not relevant to the IRC 7502 analysis -- what matters is the date on the USPS postmark or the designated PDS delivery record. If a third-party agent tenders the document to USPS or a designated PDS on the due date and a dated acceptance receipt is issued, IRC 7502 applies. If the agent uses its own courier system (not USPS and not a designated PDS), the delivery record from that courier is not a qualifying postmark. Confirm in writing with any third-party mailing agent which delivery method will be used for each filing, and obtain and retain all dated mailing receipts. Verify current third-party mailing procedures and IRC 7502 requirements at IRS.gov and in Treas. Reg. 301.7502-1.
What should a practitioner do if a client's mailing receipt has been lost?

If the original mailing receipt is lost, the practitioner has secondary options: USPS can verify a certified mail item's mailing and postmark date through its tracking systems using the article number; and for registered mail, USPS maintains detailed records at each transfer point accessible by formal request. Without any receipt or corroborating evidence, the common-law mailbox rule requires proving by a preponderance of the evidence that the document was properly mailed -- a difficult burden when the IRS claims non-receipt. Prevention is the only reliable solution: retain mailing receipts indefinitely for every deadline-sensitive tax filing and maintain an office log recording the mailing date, recipient, article type, article number, and the filing it corresponds to.
Does IRC 7502 apply to documents sent to the Tax Court or only to the IRS?

IRC 7502 applies to Tax Court petitions because filing a petition with the Tax Court is a procedure under the Code (IRC 6213(a)). Tax Court Rule 22 codifies the IRC 7502 framework for petitions filed by mail or designated PDS. A petition postmarked (USPS) or recorded by a designated PDS (Notice 2023-36) on or before the 90th day is treated as timely filed with the Tax Court, even if physically received after that date. Petitions filed through the Tax Court's eFiling system receive a filing date based on the electronic system's acceptance timestamp. Always confirm the correct Tax Court mailing address at ustaxcourt.gov before filing, and retain all proof of mailing.

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This guide is published by Americas Tax for general informational and educational purposes only. It does not constitute legal advice, tax advice, or a representation of any specific outcome. IRC 7502, Notice 2023-36, and related IRS guidance are subject to change; always verify current requirements at IRS.gov and with a qualified tax professional before acting on any information contained in this guide. Americas Tax makes no representations regarding the completeness or accuracy of IRS-approved private delivery service lists or PDS service names, which change over time. Verify the current approved PDS list directly against the current IRS notice at IRS.gov before each filing.