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Income Taxes › Statute of Limitations

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Smith Anderson

Franchise Tax Refund Opportunity

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Corporations subject to North Carolina’s franchise tax have an opportunity to seek refunds of their 2021 and 2022 franchise taxes but should act promptly to preserve their rights....more

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

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What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Allen Barron, Inc.

Tax Updates and Information for US Expatriates

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US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more

Allen Barron, Inc.

What Are the Statute of Limitations on an IRS and California Tax Audit?

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What are the statute of limitations on an IRS audit and a California tax audit? There is a time limit, known as the “statute of limitations“, when the IRS and/or California must complete an audit of your tax returns. It is...more

DarrowEverett LLP

IRS Response to Israel’s Declaration of War: Relief to Impacted Taxpayers, But Extensions Granted to Its Enforcement Arm

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In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks...more

Dickinson Wright

IRS Orders Immediate Stop to New Employee Retention Credit Claims and Announces Future Settlement Program

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The Employee Retention Tax Credit (“ERC”), enacted as a part of the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”), is a fully refundable tax credit for employers, which is up to $26,000 per eligible...more

Freeman Law

Tax Court in Brief | Fairbank v. Comm’r | Reporting Obligations for Foreign Trust Income and Ownership; Statute of Limitations

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Summary:  At its core, this 31-page opinion regards married U.S. citizen taxpayers, Leigh Fairbank (Leigh) and Barbara Fairbank (Barbara), challenge to deficiency notices issued for the tax years in issue (2003 through 2009...more

Freeman Law

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

Freeman Law on

Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary:  Eric Schwartz (“Schwartz”) and his spouse divorced.  Pursuant to those divorce proceedings, the state court...more

Gerald Nowotny - Law Office of Gerald R....

Ten Years After - The IRS Collection Statute of Limitations

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I was a youngster for the Woodstock Music and Art Fair commonly known as Woodstock took place in Bethel, NY between August 15-18, 1969. Frankly, I never knew anyone growing up in the Canal Zone that attended in person. The...more

Freeman Law

Criminal Tax Statutes of Limitations and Suspensions: 18 U.S.C. § 3292 and the Fifth Circuit’s Decision in Pursley

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In civil and in criminal cases, the Government must generally act within a certain prescribed time to take action against taxpayers. In legal parlance, this period of time is known as the “statute of limitations.” The...more

Blank Rome LLP

State Barred by Statute of Limitations from Recovering an Erroneous Refund Payment

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The New Jersey Tax Court recently granted a pro se taxpayer’s motion for summary judgment and ruled that the Division of Taxation was barred by the statute of limitations from recovering an erroneous income tax refund payment...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

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We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

Freeman Law

Protective Refund Claims: Preserving the Right to a Tax Refund

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When is a protective refund claim available?  Taxpayers often face uncertain outcomes in litigation or business transactions, giving rise to contingent tax refund claims.  For example, if a pending lawsuit ends in a favorable...more

Gray Reed

Statute of Limitations in Tax Cases – The Basics

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What is the Statute of Limitations? - The Internal Revenue Code limits the time in which the government may assess tax. There are two civil statutes of limitations.  The first is the period during which the IRS can assess...more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

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In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

Freeman Law

Can You Transfer Assets to Avoid Paying Taxes to the IRS?

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In many cases, taxpayers attempt to transfer assets or property to third persons to shield those assets and property from the federal tax lien or federal tax levy. Predictably, the IRS has various tools at their disposal to...more

Hogan Lovells

Spain: Law 11/2021 implementing ATAD and other measures against fraud

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The Spanish Parliament has finally approved Law 11/2021, of 9 July, on measures to prevent and fight against tax fraud (“Law 11/2021”) which implements several aspects of Council Directive (EU) 2016/1164 of 12 July 2016...more

Freeman Law

The Tax Court in Brief - July 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of July 5 – July 9, 2021 - Peterfreund v. Commissioner,...more

Freeman Law

The Tax Court in Brief - June 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of June 14 – June 18, 2021 - Bell Capital Management, Inc....more

Ballard Spahr LLP

Philadelphia Ordinance Requires Reporting of Federal Tax Changes

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Philadelphia City Council enacted Ordinance No. 210139-AA (the Ordinance; available here), effective immediately, requiring all Philadelphia taxpayers to report any changes to their federal taxable income to the Philadelphia...more

Holland & Knight LLP

When Is a Tax Return "Filed"?

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In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

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Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

Freeman Law

Everything That You Need To Know About International Tax Penalties

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International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

Ward and Smith, P.A.

Temporary Relief for NC Taxpayers Under New COVID-19 Legislation

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Members of the North Carolina General Assembly made good use of their time leading up to the short session that began on April 28, with each chamber filing a COVID-19 relief bill within twenty-four hours of reconvening....more

Foster Garvey PC

The IRS Will Put the American People First — No, Really (But Only for a Limited Time)

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Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more

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