There has been widespread confusion regarding the requirement to file Form 1120 Schedule O. Schedule O is only required to be included with corporate returns for tax years beginning on or after December 22, 2006. The printed paper instructions for Schedule O inadvertently omitted the effective date for Schedule O. Even though Schedule O is not required, you can voluntarily complete and file Schedule O for tax years beginning prior to December 22, 2006.
The Modernized e-File (MeF) system has Business Rule F1120-269 which states:
If Form 1120, Schedule J, Line 1 checkbox is checked, then Schedule O (Form 1120) must be attached to the return.
Business rule F1120-269 has been disabled so that corporate returns that with tax years beginning prior to December 22, 2006 will not be rejected.
*Note: You may receive a diagnostic error in your software if you are filing a corporate return and you do not include Schedule O since some software versions may not yet have been updated to reflect this change. The diagnostic error will NOT cause your return to be rejected by the IRS.
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