2023 Tax Credit issue and what you can do about it.

[AEtherScythe]

The IRS has a "Systemic Advocacy Management System (SAMS)" which is intended to address issues where a hardship affects a class of tax payers.
For this purpose new owners of Ford Mustang Mach-E's, purchased aftier 1/1/2023 should qualify.

Please join me in filing a complaint as follows, starting here:

https://www.taxpayeradvocate.irs.gov/contact-us/submit-a-request-for-assistance/

Use your own words. This is what I said.

Select a role that best describes your position: *
Select an option:

A Taxpayer


Enter your location:

(Your State)


Enter your email address:

(Your e-mail)


Briefly describe your issue: *

Incorrect vehicle criteria applied for 2023 New Qualified Clean Vehicles Tax Credit


Detailed description: *

Starting at this site:

https://www.irs.gov/credits-deducti...ied-clean-vehicles-purchased-in-2023-or-after

Please note the table under Ford Motor Company. The Ford Mustang Mach-E is incorrectly classified as a car ($55K limit), even though the DOE / NHTSA's own VIN decoder classifies the car as a Sport Utility Vehicle (SUV)/Multi-Purpose Vehicle (MPV) e.g. $80K limit.

Those affected assert that the IRS should not arbitrarily assign vehicle body classes, but should instead defer to the DOE / NHTSA's already well established classification of vehicles.

Here is a VIN you can use for reference at the NHTSA decoder site, here:

https://vpic.nhtsa.dot.gov/decoder/Decoder

VIN: (Your VIN for a MME purchased after 1/1/2023)

Note that NHTSA indicates that the Ford Mustang Mach-E is a Sport Utility Vehicle (SUV)/Multi-Purpose Vehicle (MPV) e.g. $80K limit for vans, sport utility vehicles and pickup trucks, not a $55K limit for other vehicles.

On the IRS website (noted above at the top of this complaint), there are smaller Electric Vehicles in the same SUV class as the Ford Mustang Mach-E, which the IRS is arbitrarily assigning SUV status.

This practice of the IRS arbitrarily classifying vehicles independently of the DOE / NHTSA's classification is unfair and represents a hardship to the many thousands of Ford Mustang Mach-E owners due to these new 2023 rules being incorrectly assigned / administered by the IRS.

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[cryptk]

Here is the one that I just submitted, I "borrowed" your last two paragraphs:

Brief description: Vehicle classification for 30D is incorrect, conflicting with multiple other agencies, and arbitrary

Detailed description:
Based on the current list on this site: https://www.irs.gov/credits-deducti...ied-clean-vehicles-purchased-in-2023-or-after these vehicle classifications are arbitrary, and in many cases conflicting with other government agencies.

One such example is the Ford Mustang Mach-E. This vehicle is categorized as an SUV by the EPA/DOT based on the monroney/window sticker. It is categorized as an SUV/MPV by the NHTSA based on their online VIN decoder available at https://vpic.nhtsa.dot.gov/decoder (you can search for VIN <CENSORED> as an example VIN for a 2023 Mustang Mach-E and reference the 'Body Class' section of the results). It is also classified as an SUV by Ford, the manufacturer of the vehicle.

In fact the only group that I can find that does not classify this vehicle as an SUV appears to be the IRS, with no explanation given as to why you disagree with the manufacturer and every other government agency.

The Tesla Model Y also suffers from this as having 2 fewer seats making it a 5 passenger vehicle vs. a 7 passenger vehicle (with no other changes to the vehicle) somehow changes it from an SUV to 'not an SUV'.

This will unduly impact taxpayers who ordered these vehicles under the belief that they are an SUV (because everything, including government agencies, says they are), only to have the IRS disagree at the last minute and proclaim that they are not an SUV, reducing the MSRP cap from $80k to $55k.

On the IRS website (noted above at the top of this complaint), there are smaller Electric Vehicles in the same SUV class as the Ford Mustang Mach-E, which the IRS is arbitrarily assigning SUV status.

This practice of the IRS arbitrarily classifying vehicles independently of the DOE / NHTSA's classification is unfair and represents a hardship to the many thousands of Ford Mustang Mach-E owners due to these new 2023 rules being incorrectly assigned / administered by the IRS.

 

[sim1]

I applaud the effort. But I would rethink the angle of attack. These weren't arbitrary classifications. Stupid, inane, ridiculous--sure, but not arbitrary.

 

[Jax_GT]

I applaud the effort. But I would rethink the angle of attack. These weren't arbitrary classifications. Stupid, inane, ridiculous--sure, but not arbitrary.

Yep. It’s by weight and/or ground clearance. Unless they change those classifications it’s not going to change. Hopefully they can adjust those, but as sim1 mentioned it wasn’t just randomly done.

A MME feels like an suv but has a ground clearance similar to the “real” Mustang. I’ve always seen them as more of a hatchback than an SUV.

I hope they adjust the classifications, but it’s going to be an uphill battle.

 

[theriddler]

Yep. It’s by weight and/or ground clearance. Unless they change those classifications it’s not going to change. Hopefully they can adjust those, but as sim1 mentioned it wasn’t just randomly done.

A MME feels like an suv but has a ground clearance similar to the “real” Mustang. I’ve always seen them as more of a hatchback than an SUV.

I hope they adjust the classifications, but it’s going to be an uphill battle.

So does the Model Y (5 seater) have a different ground clearance than the Model Y (7 seater) because the 5 seater is classified as a car and the 7 seater is classified as an suv when they are the exact same vehicle other than the interior makeup change?

 

[Jax_GT]

So does the Model Y (5 seater) have a different ground clearance than the Model Y (7 seater) because the 5 seater is classified as a car and the 7 seater is classified as an suv when they are the exact same vehicle other than the interior makeup change?

I think that has to do with weight, or maybe the seat count. Seven seats is above what a normal car would have.

 

[phil]

I don't understand this comment. The IRS is renowned the whole world over for its compassion, empathy, and unrivaled milk of human kindness.

 

[theriddler]

I think that has to do with weight, or maybe the seat count. Seven seats is above what a normal car would have.

I guess it is possible...I think it is more likely due to the fact that the IRS is run by a group of people who are designed to follow steps as trained and not be able to think freely or logically.

 

[4sallypat]

So does the Model Y (5 seater) have a different ground clearance than the Model Y (7 seater) because the 5 seater is classified as a car and the 7 seater is classified as an suv when they are the exact same vehicle other than the interior makeup change?

If you look at the GVWR, the 7 seater Tesla along with VW's iD4 Pro S AWD comes in at over 6000 lbs.

MME does not reach 6000 lbs.

 

[Logal727]

Yep. It’s by weight and/or ground clearance. Unless they change those classifications it’s not going to change. Hopefully they can adjust those, but as sim1 mentioned it wasn’t just randomly done.

A MME feels like an suv but has a ground clearance similar to the “real” Mustang. I’ve always seen them as more of a hatchback than an SUV.

I hope they adjust the classifications, but it’s going to be an uphill battle.

they should do driver placement height instead of ground clearance, the driver platform doesn't start for a bit because of the battery pack. Heck, I was the sitting the same height in my Honda Odyssey as I do in my MME

 

[theriddler]

If you look at the GVWR, the 7 seater Tesla along with VW's iD4 Pro S AWD comes in at over 6000 lbs.

MME does not reach 6000 lbs.

I do not believe that is correct on tesla my. I can find nowhere that has the weight of that vehicle over 5000 pounds, regardless of the seating configuration. But I am not arguing over the issue. My original point was that the arbitrary distinction between the 7 seater as an suv and the 5 seater as a car is as ridiculous as the MME being classified as a car while the escape is classified as an suv.

 

[AEtherScythe]

Good news!

https://news.bloomberglaw.com/daily...lify-for-tax-credits-after-us-reverses-course

Also, I spoke with the IRS directly today and it turns out they received "several" complaints of a similar nature to the one that I proposed. ;-)
They all got consolidated and escalated.

I would like to think that we all had a small part in the outcome here, in addition to the reported "pressure" from the auto manufacturers.

Either way, justice is done! =D =D =D

 

[AEtherScythe]

Incidentally, in prepping to talk to the IRS, I had started to arm myself with research about the prior "arbitrary" classifications.

Since it's all moot now, I don't see an issue with publicizing my research.
Partial as it was it did expose quite a few discrepancies.

Most noteworthy is that the Tesla Model Y 7-seater is precisely the same car as the 5-seater, but with an interior mod to allow a third row of seats in the cargo area. And the 7-seater actually has LESS CARGO SPACE than the 5-seater. Both are the same height, ground clearance, and roughly the same weight.

I mainly concentrated just on Tesla and Ford, because what was happening there was so blatantly unfair for what are essentially the same class of vehicle.

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