Ok----this was all re-the same question so would not require being closed out & starting a new thread. Except you were now asking for an interpretation of the meaning of some internally used code words. As you can imagine, that is an entirely different line of research, unrelated specifically to SOL. Trust me, been doing legal work for 18 years...
You did a great job answering my question----Thank you.
FYI--the reason I am being so nit-picky abut pinning down the date is that I submitted 2 offers and the 1st time they 'sat' on it for 18 months Which I understand is OK, however annoying...
& the 2nd for 23 mo! Under 24 months also... Which rule are you arguing they violated? which totally against (their) rules -with the statute tolling for a total of 41 months with no recourse. There can be many tolls, depending on case actions taken by a taxpayer.
All of this time I have a partial payment installment agreement -- Great! ---with significant payments each month---which is another violation--should be suspended. Unless in that agreement, or connected to it, there was a provision for extension of the CSED... But if not, you could use that as an affirmative defense and defeat any lawsuit, you agree?
Just thought you could use this experience in helping other clients of yours. I have had many skirmishes with them and won most of them.Congratulations :)
4 keys to success-
1. Lawyer up Specificially, use a tax lawyer.
2. Do your own homework---don't just take your lawyers word for it--- always a good idea.
they are correct apprx 50% of the time. Really? You have had a tax lawyer that misguided you as per the laws? Sounds like malpractice to me, if damages resulted to you.
3. Don't believe the IRS---they play fair----but very often don't even know their own codes---sometimes have to clarify things for them. Does that mean you got your CSED corrected based on no extension due to PPIA?
4. Have big balls! Lol, or big something else, if the shoe fits :)