Statutes of Limitations and Mitigation of the Statutes of Limitations
This unique course covers a very confusing area of tax compliance. There are many situations where the statute of limitations differs from the 3-year period. Additionally there are relief provisions for both the taxpayer and the IRS if the statute has expired and it results in inconsistent treatment for either party.
Due to its budgetary crisis, it is difficult to get guidance from the Internal Revenue Service. Taxpayers and tax professionals alike must now fend for themselves by researching the IRS website for information.
How long can the IRS pursue an examination or collection action? Is it possible to advise the IRS that it does not have the legal authority to assess a tax and to ask it to please refrain from action against you, your business, or your client?
This class will cover the impact of a net operating loss and the impact of a carry back on normally closed years. It will also cover IRS policies relating to extended failure to file situations and Internal Revenue Code sections 1311, 1312, and others that provide relief to taxpayers.
Stu Sobel shares his 48 years of tax wisdom. He retired from the IRS after working for 30 years in examination and high-level management positions. He has written four books on taxation and trained thousands of tax professionals around the world.
This course will cover the following topics:
- Statutes of limitations for many different types of tax situations
- Advice on whether or not to extend the statute of limitations in a tax controversy situation
- Impact of a net operating loss on the statute of limitations
- How to advise the IRS that a statute of limitations has expired and that the IRS is prohibited from assessing tax
- Filing protective claims for refund in order to protect the statute of limitations in the taxpayer’s favor
- Utilizing the mitigation of statute of limitations provisions to protect the taxpayer from inconsistent IRS treatment
- Understand the different statutes of limitations for assessment and collection
- Acquire techniques that can be used to avoid inconsistent treatment by the IRS
- Learn how to use the IRS website to research solutions to complicated statute of limitations questions
NASBA & IRS field of study: Taxes
CPE Credit: 1 hour
Length: 1 hour
Advanced preparation: None
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