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There is so much that doesn’t make sense here and no treatise on earth will quickly give you the knowledge you need to even know the right questions to ask let alone handle this. Find a senior tax controversy attorney in your firm to handle this or refer elsewhere.
I’m so confused by your question. Are we talking amended 1040s? So 1040xs? Are we talking foreign filings. And what years were owed vs what years were refunds? Was this amended as part of a voluntary disclosure potentially? So many questions
Yeah, just off the top of my head, isn’t it only three years? Or if it’s part of a voluntary disclosure (which I don’t know if it is), would that impact filing refund claims?
I agree with the above. Your question makes no sense and lacks material detail. I’m a tax litigator.
That’s honestly pretty much all I was given as a starting point. Just curious, what more would be needed to answer a question like this? I think the partner thought this would be more straightforward i.e. whether a taxpayer can only pay the tax owed and none of the interest that has accrued for the time being and then file a refund claim for the 2 tax years in question.
There’s a lot of confusion but I think the crux of your question is about paying just tax due with no interest. Interest is statutory and not waivable. Paying the tax due without interest will not be enough to cover the entire amount due for that year.
Yeah, that’s what I figured. I don’t see how a taxpayer can just pay the tax owed and not the interest that has accrued. Pay the tax owed and interest accrued and then file a refund claim for both the tax owed and interest accrued. I’ve never heard of a taxpayer just being able to pay the tax owed and none of the interest
Flora and it’s progeny may have some similar fact patterns
Yep, that’s exactly what I found (Flora, Shore, etc). Thank you for this! Really appreciate this tax bowl
Late to the party, but this is exactly what I do.
The IRS has 10 years from the date of assessment to collect tax. The date of assessment is the date the balance due is 'entered onto the books of the United States,' and is NOT the filing date, but typically 1-4 weeks later. The collection statute expiration date (CSED) can be tolled by things like OICs, Installment requests, etc.
Under 26 USC 6020, the IRS can prepare a return, which starts the CSED clock, but it's optional. If that doesn't happen, and the return has not been filed, the clock never starts. The parties can also agree to extend the statute by filing form 872.
For refunds, it's a much shorter statute - 2 years from the date the tax was paid or 3 years from the due date.
Amended returns extend the CSED for the amended portion. Also, where NOLs exist, the statute remains open for all years to which the NOL applies, but only WRT the NOL.
This is a short, quick answer. For a more specific one, DM me.
If anyone has recs on treatises/secondary sources for individual income tax questions, I’d appreciate it
Seconding all these other comments, but I’d fire up BNAs on Bloomberg for at least a starting point. Godspeed.
Mertens Law of Federal Income Taxation was always my go to when I first started. Since then I hit up the treatises and sources on Checkpoint but Bloomberg is also a good source.