Whose Fraud Is It Anyway? The Expanding Reach of the Fraud Exception to the Statute of Limitations on Tax Assessment

Vinson & Elkins LLP
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Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on taxpayer misconduct.

Originally Published in Taxes Magazine - November 2025.

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