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Tax

Jun. 21, 2013

Courts disagree when it comes to tolling tax statute

How much time does the Internal Revenue Service have to assess taxes? This simple question is put to tax lawyers and accountants all the time, but the answer isn't always simple. By Robert W. Wood and Dashiell C. Shapiro

Robert W. Wood

Managing Partner
Wood LLP

333 Sacramento St
San Francisco , California 94111-3601

Phone: (415) 834-0113

Fax: (415) 789-4540

Email: wood@WoodLLP.com

Univ of Chicago Law School

Wood is a tax lawyer at Wood LLP, and often advises lawyers and litigants about tax issues.

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By Robert W. Wood and Dashiell C. Shapiro


How much time does the Internal Revenue Service have to assess taxes? This simple question is put to tax lawyers and accountants all the time, but the answer isn't always simple. Usually it is three years, in some cases it is six years, and sometimes it is even more.


Then there is the IRS collection statute, which is generally 10 years. But that assumes the taxes were validly and timely assessed. Most of th...

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