Notice 2025-53

SECTION I. PURPOSE

This notice provides relief under section 7508A of the Internal Revenue Code ¹ for persons that the Secretary of the Treasury has determined to be affected by the terroristic action in the State of Israel throughout 2024 and 2025. The Department of the Treasury and the Internal Revenue Service (IRS) may provide additional relief in the future. For taxpayers who were “Affected Taxpayers” for purposes of Notice 202472, 2024-43 IRB 1005 (October 21, 2024), including taxpayers who were “Affected Taxpayers” for purposes of both Notice 2024-72 and Notice 2023-71, 2023-44 IRB 1191 (October 30, 2023), the separate determination of terroristic action and grant of relief set forth in this notice will also postpone taxpayer acts and government acts already postponed by Notice of 2024-72, including acts postponed by both Notice 2024-72 and Notice 2023-71, if the taxpayer is eligible for relief under the applicable notices.

SECTION II. BACKGROUND

Section 7508A(a) provides the Secretary of the Treasury or the Secretary’s delegate (Secretary) with authority to postpone the time (up to one year) for performing certain acts under the internal revenue laws for a taxpayer determined by the Secretary to be affected by a terroristic or military action as defined in section 692(c)(2). Section 692(c)(2) defines a terroristic action as “any terroristic activity which a preponderance of the evidence indicates was directed against the United States or any of its allies.”

Section 4.01(1) of Revenue Procedure 2004-26, 2004-1 C.B. 890, provides that prior to publishing a determination that an event outside the United States constitutes a terroristic action within the mean

ing of section 692(c)(2), the Secretary will ascertain whether the Department of State and the Department of Justice believe that a preponderance of the evidence indicates that the event resulted from terrorist activity directed against the United States or its allies. On September 30, 2025, in accordance with the procedures described in Rev. Proc. 2004-26, the Secretary of the Treasury determined that the terrorist activity throughout 2024 and 2025 against the State of Israel constitutes terroristic action within the meaning of section 692(c)(2).

SECTION III. GRANT OF RELIEF

With respect to taxpayers described in section III.A of this notice (affected taxpayers), this notice postpones the due dates for the actions described in section III.B and III.C of this notice until September 30, 2026 .

A. Affected Taxpayers

Section 301.7508A-1(d)(1) describes several types of “affected taxpayers” eligible for relief under section 7508A. The Secretary of the Treasury has determined that the following types of taxpayers are affected taxpayers with respect to the terroristic action eligible for the relief provided in this notice:

• Any individual whose principal residence, and any business entity or sole proprietor whose principal place of business, is located in the State of Israel, the West Bank or Gaza (covered area);

• Any individual affiliated with a recognized government or philanthropic organization and who is assisting in the covered area, such as a relief worker;

• Any individual, business entity or sole proprietor, or estate or trust whose tax return preparer or records necessary to meet a deadline for postponed acts are located in the covered area;

• Any spouse of an affected taxpayer, solely with regard to a joint return of two married individuals; and

• Any individual visiting the covered area who was killed, injured, or taken hostage as a result of the terroristic action.

1 Unless otherwise specified, all “Section” or “§” references are to sections of the Internal Revenue Code or the Procedure and Administration Regulations (26 CFR part 301).

October 20, 2025 624 Bulletin No. 2025–43

time-sensitive actions with respect to affected taxpayers. Any government acts described in § 301.7508A-1(c)(2) that are due to be performed on or after September 30, 2025, and before September 30, 2026, are postponed until September 30, 2026. These acts include:

• Assessing any tax;

• Giving or making any notice or demand for the payment of any tax, or with respect to any liability to the United States in respect of any tax;

• Collecting by the IRS, by levy or otherwise, of the amount of any liability in respect of any tax; and

• Bringing suit by the United States, or any officer on its behalf, in respect of any liability in respect of any tax; and allowing a credit or refund of any tax.

SECTION IV. INTERACTION WITH NOTICES 2023-71 AND 2024-72