White Paper

IRS Tax Audits - Assessment of Tax-Collection

 
“Under IRC 6501(a), the amount of tax imposed shall be assessed within 3 years after the tax return was filed (or 3 years after the date on which any part of such tax was paid). Effectively, the IRS has 3 years to audit a filed tax return (tax paid) "assess" additional tax due, and seek collection of additional tax due. The 3-year basic assessment statute of limitations rule has two primary exceptions:

1) 6 years after the tax return is filed for an omission of 25% or more of gross income;

2) "Forever" in the case of civil tax fraud and/or failure to file tax returns.

The general rule of 3 years to assess tax is subject to the following exceptions under IRC 6501 (c):

1) False tax return (fraudulent tax return): tax may be assessed at any time (IRC 6501 (c) (1);

2) Willful Attempt to Evade Tax: tax may be assessed at any time (IRC 6501 (c) (2);”

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Our author, Gary S. Wolfe, has more than 34 years of experience, specializing in IRS Tax Audits and International Tax Planning/Tax Compliance, and International Asset Protection.

Faculty

Gary S. Wolfe

The Wolfe Law Group

Agenda

Faculty

Gary S. Wolfe

The Wolfe Law Group

Our author, Gary S. Wolfe, has more than 34 years of experience, specializing in IRS Tax Audits and International Tax Planning/Tax Compliance, and International Asset Protection.

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