- New USPS rules provide that an official postmark date will not necessarily match the date on which the mail piece was collected by a letter carrier or dropped off at a retail location. This could result in missing tax filing or payment deadlines.
- Taxpayers and tax professionals should request a manual postmark when sending time-sensitive mail by the USPS or by using Certified Mail.
Background
On November 24, 2025, the Postal Service published a notice in the Federal Register announcing the addition of section 608.11, “Postmarks and Postal Possession,” to the Domestic Mail Manual (DMM). The new section explains what constitutes a postmark, specifies which United States Postal Service (USPS) markings qualify as postmarks, and outlines the circumstances in which those markings are applied. It also provides guidance on how customers can obtain proof of the date on which the USPS takes custody of their mail. These changes, made effective as of December 24, 2025, may complicate tax filings made through the USPS and require additional measures to ensure they are filed timely.
How does this impact tax filings?
Section 7502 of the Internal Revenue Code provides the requirements for timely filings and payments. Specifically, the section states that the USPS postmark stamp determines the date of delivery or payment as required under the applicable internal revenue law.
The new section of the DMM clarifies that an automated machine-applied postmark will be applied at Regional Processing and Distribution Centers (RPDC) and Local Processing Centers (LPC). These locations may be different from the location where the USPS originally obtained possession of the mailpiece; therefore, the notice states, “the postmark date does not inherently or necessarily align with the date on which the Postal Service first accepted possession of the mailpiece.” This could be problematic for tax filings as the date the mailpiece was delivered to an USPS office, retail location, or by letter carrier, may not be the same day the mailpiece is postmarked. The taxpayer would have no control on determining when the filing arrives at an RPDC or LPC, and thereby postmarked, after it is delivered or picked up.
Forvis Mazars Insight: Section 608.11 was introduced under the Delivering for America (DFA) plan.1 The DFA plan consolidates mail processing from a more decentralized network of sectional center facilities into regional processing and distribution centers servicing much larger territories. This may result in mail being moved over a hundred miles away from the drop-off site before being processed.
Actions to Consider
While it is ideal to file returns or make any payments electronically to avoid the postmark issue, there are various situations where paper filing is the only option. For any time-sensitive items that are required to be mailed to the IRS or to state or local jurisdictions (e.g., paper returns, check payments, audit protest letters, etc.) it is important to ensure they are mailed timely by obtaining a postmark. This is especially important in disputes between a taxpayer and tax collection authorities, where a missed deadline does not simply result in a penalty, but in protest rights and/or refund periods lost.
The USPS advises customers who want a postmark aligning with the date on which the postal service first accepted possession of their mail piece to pursue one of the following:
- Purchase a Certificate of Mailing. Registered Mail and Certified Mail services also provide mailing receipts for individual mailpieces.
- Request a manual (local) postmark free of charge at any USPS office, station, or branch when tendering their mailpiece. These indicate the location and date of acceptance at the delivery location. Customers planning to present significant mail volume (50 or more mailpieces) should contact the postmaster or manager in advance to ensure adequate resources are available.
- Postage Validation Imprint (PVI) labels, which are printed and applied by USPS employees at the retail counter at any USPS office, station, or branch to a mailpiece. These indicate the postage paid, the location, and the date of acceptance at the retail unit.
Forvis Mazars Insight: To avoid the postmark issue with USPS, individuals may want use private delivery services designated by the IRS to meet the “timely mailing as timely filing/paying” rule for tax returns and payments. Currently, these private delivery services only include DHL Express, FedEx, and UPS. Taxpayers should also be cautioned that self- applied pre-printed labels, postage printed from self-serve kiosks, postage printed online, and meter strips do not constitute a postmark.
How Forvis Mazars Can Help
If you have any questions on how this may impact your tax return filings, please contact a Forvis Mazars professional.
- 1“Delivering for America,” usps.com