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USTaxAdvising, CPA
Category: Tax
Satisfied Customers: 1237
Experience:  US Taxation specialist.
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on a contested tax penalty how do the statutes of limitation

Customer Question

on a contested tax penalty how long do the statutes of limitation run and when does the time period start
Submitted: 5 years ago.
Category: Tax
Expert:  USTaxAdvising replied 5 years ago.

The IRS generally has ten years from the date of assessment to collect the tax from you. If you are under litigation the statute of limitations does not run while litigation against the IRS is pending.(i.e. the tax penalty cannot expire)


If the IRS does not collect the tax within ten years, it may be barred from attempting to collect from you. There are ways that the ten year period can be extended, including the filing of an Offer in Compromise, the filing of a bankruptcy, signing a waiver or others. Unfortunately, the collection statute of limitation does not begin to run until you file your tax return or an assessment is made.

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Customer: replied 5 years ago.
can you tell me the US code/statute number that relates to the above statute of limitations
Expert:  USTaxAdvising replied 5 years ago.

Yes here they are -


Section 6501 (3-year audit statute),

Section 6502 (10-year debt collection statute), and

Section 6511 (3-year refund statute).