Statute of limitations, including but not limited to:

  • General 3 year assessment statute;
  • 6 year assessment statute for 25% omissions;
  • Disclosing items to prevent 6 year statute;
  • Unlimited statute for false returns, returns attempting to evade tax, or no return;
  • Resolving matters in appeal that removed the unlimited statute, and thus, removed the entire year’s assessments;
  • Extension of time to statute of limitations pursuant to Form 872;
  • Advising on issuance of statutory notice of deficiency and tolling of statute;
  • General 10 year collection statute;
  • Filing timely claims for refund within 3 years from the time the return was filed or 2 years from the date the tax paid, whichever is later;
  • Adequacy of claim for refund, and successfully arguing the doctrine of variance;
  • Filing formal and informal claims for refund;
  • Advising on payments versus deposit distinction;
  • Filing suits for denied claims for refund; and
  • Arguing equitable recoupment, as well as mitigation provisions.