Taxpayer allowed extension to file for foreign earned income exclusion due to special circumstances.

Nonprofit and Church Legal Trends - Free Edition - May June 2007 (free edition)

The taxpayer must have acted in good faith as indicated by these types of factors: he discovers the problem and notifies the IRS before the IRS discovers it, he failed to make the election due to factors beyond the taxpayer’s control, he failed to make the election because the taxpayer wasn’t aware of the necessity of the election due to her experience and the complexity of the issue (there may be situations where ignorance of the law is an excuse), he reasonably relied on the written advice of the IRS, or he reasonably relied on a qualified tax professional who failed to advise the taxpayer to make an election.