What to Do If the IRS Files a Substitute for Return (SFR)

Marc Boulanger • May 21, 2025
A robot is talking to a boy who is holding a piece of paper.

If You Didn't File—The IRS Filed for You (and It Won’t Be Pretty)


If you haven’t filed a tax return in several years, the IRS might file one for you. This is called a Substitute for Return (SFR)—and it’s rarely in your favor.


The IRS doesn’t take your deductions, dependents, or business expenses into account. Instead, they file the most basic version of your return based on W-2s, 1099s, and 3rd-party data—often overstating your income and tax liability.


In this post, we’ll explain what an SFR is, what to do if you’ve received one, and how to reduce the inflated tax balance before collections begin.


What Is a Substitute for Return (SFR)?


An SFR is a return the IRS prepares when:


  • You haven’t filed a required return
  • They have third-party data showing income
  • They want to assess and collect tax


You’ll typically receive a Notice CP2566, CP3219N, or a Letter 2566 stating that the IRS has proposed a return on your behalf.

If you do nothing, the IRS finalizes the return and begins collections.


Why SFRs Are So Dangerous


  • No deductions – They assume standard filing with no itemized deductions
  • No dependents – Even if you have kids, you won’t get the Child Tax Credit
  • No business expenses – Self-employed taxpayers are hit hardest
  • Automatic penalties and interest – These begin accruing immediately
Related: Facing Back Taxes? Here’s How Orange County Residents Can Get Relief

Step 1: Don’t Ignore the Notice


If the IRS sent you a proposed SFR notice, you usually have 30 days to respond. You can:


  • Provide the missing tax return
  • Challenge the SFR using Form 870 or Form 4549
  • Request an audit reconsideration (if the SFR was finalized)
Related: What Happens After an IRS Audit Assessment?

Step 2: File a Real Return to Replace the SFR


The best move is to file your actual tax return for that year—even if it's late.


This return should:


  • Include all valid deductions and credits
  • Show your correct filing status and dependents
  • Be signed and dated
  • Include a written explanation, if needed


The IRS may accept your return in place of the SFR and reduce your liability significantly.


Step 3: Resolve the Balance


Even after you replace the SFR, you may still owe tax. At that point, you can:



The key is to act before the IRS moves to levy your wages or accounts.


Step 4: Prevent Future SFRs


To avoid additional Substitute for Return assessments:


  • File any remaining back returns
  • Stay current with all future filing deadlines
  • Respond promptly to IRS notices


The longer you wait, the harder it is to reverse SFR damage.


We Help Orange County Taxpayers Reverse SFRs and Settle Back Taxes


At Boulanger CPA and Consulting PC, we help clients:


  • Replace IRS SFRs with properly prepared returns
  • Reduce tax balances inflated by substitute filings
  • Stop IRS collections
  • Set up affordable resolution strategies


Call (657) 218-5700 or book online at www.orangecounty.cpa.


We’re local, experienced, and ready to help.


Frequently Asked Questions

  • Will the IRS cancel an SFR if I file a return?

    Often yes—especially if you act before the SFR is finalized. Even afterward, audit reconsideration may be possible.

  • What if I owe more after filing my real return?

    It happens occasionally, but most real returns reduce the SFR balance.

  • Can I still claim deductions and credits on a late return?

    Yes, but certain credits may expire if too much time has passed.

  • Will the IRS garnish my wages after an SFR?

    Yes—if you don’t respond, the IRS may pursue wage garnishment or bank levies.




📣 About the Author


Marc Boulanger, CPA is the founder of Boulanger CPA and Consulting PC, a boutique tax resolution firm based in Orange County, California and trusted by high-income individuals and business owners across Southern California.


With over a decade of experience resolving high-stakes IRS and State tax matters, Marc brings strategic insight to complex cases involving wage garnishments, bank levies, unfiled returns, and six-figure tax debts. He is known for helping clients reduce or eliminate tax liabilities through expertly negotiated settlements and compliance plans.


Marc is a Certified Public Accountant licensed in California and Oklahoma and holds the designation of Certified Tax Representation Consultant. He is a member of the American Society of Tax Problem Solvers (ASTPS) — the national organization founded by the educators and practitioners who have trained thousands of CPAs, EAs, and tax attorneys in IRS representation strategy.


Every case is handled with discretion, proven methodology, and direct CPA-led representation — not call center scripts.


📍 Learn more at www.orangecounty.cpa or call (657) 218-5700.


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