As a general rule, the time period within which assessments may be made is three years from the date that the return was filed. If a return was filed early, this time period is reckoned from the due date of the return, not the date that the return was actually … [Read more...]
IRS Tax Collection & Tax Debt Resolution Articles
Articles about IRS tax collection and tax debt resolution by the Law Office of Jin Kim.
Articles about specific IRS tax resolution strategies can be found on the following category pages: offer in compromise, installment agreement, and non-collectible status.
When Can the Statute of Limitations be Tolled for Assessments?
The statute of limitations prescribes the time period within which a case may be brought on a cause of action. For assessments, the general rule is that assessments may only be brought within three years, subject to certain exceptions, after a return is filed or after the due … [Read more...]
Judicial Review of Jeopardy and Termination Assessments
The shortcut assessment procedures for tax collections deemed to be in "danger" include jeopardy and termination assessments. All the relevant provisions of the Internal Revenue Code (IRC) authorizing jeopardy and termination assessments seem favorably skewed … [Read more...]
Suit to Reduce a Tax Assessment to Judgment
Not much is written on the internet apart from the dry text of the Internal Revenue Manual about suits to reduce tax assessments to judgment. This little-known (and rarely used?) tax collection avenue is available to the IRS to effectively extend the 10-year statute of … [Read more...]
Innocent Spouse Relief: When The IRS Notifies The Non-Requesting Spouse
Once the IRS receives a taxpayer's request for innocent spouse relief, either election under 26 CFR § 1.6015-2 or equitable relief under 26 CFR § 1.6015-4, the non-requesting spouse is not left alone in the dark. The IRS must notify the non-requesting spouse of the relief … [Read more...]