Statute of Limitation

Is There Still Time to Correct IRS Interest Mistakes?

If the IRS does not refund the correct interest, what is the statute of limitation for a claim for additional interest? What is statute of limitation for a claim for refund for interest netting and how long the IRS has to assess the correct amount of deficiency interest? The answers to these questions may surprise even experienced tax professionals.

Assessment Period Remains Open in Partnership Case

In Blak Investments, the Tax Court applied Sec. 6501(c)(10) to extend the assessment statute of limitation for a taxpayer with an undisclosed listed transaction on a return due prior to October 22, 2004.

NOL Carryback Claims Can Unlock Closed Statute of Limitation Years

With the introduction of the five-year net operating loss (NOL) carryback in Sec. 172(h) as part of the Worker, Homeownership, and Business Assistance Act of 2009, taxpayers should consider the impact that carrying back an NOL has on the assessment statute of limitation.

Superseding Return Filed on Extended Due Date Starts SOL

Editor: John L. Miller, CPA The general statute of limitations (SOL) for assessment found in Sec. 6501 gives the IRS three years to assess tax after a return has been filed, beginning on the date that a valid Federal tax return is deemed filed. A return filed prior to the

Newsletter Articles


Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.


Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.