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


50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.


Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.