Derived from: Tax Procedure and Tax Fraud, Patricia Morgan, West
Publishing, p. 96; ISBN 0-314-06586-5
| Type
of Action |
Limitation
Period |
I.R.C.
§ |
| IRS assessment of tax |
Generally 3 years after due date of return
(or date actually received by IRS, ir later) |
6501(a) |
Exceptions to normal 3-year limit
1. No return filed.
2. Fraudulent return
3. Substantial omission from gross income |
No limit
No limit
6 years |
6501(c)(3)
6501(c)(1)
6501(e) |
| Claim for refund of overpaid
tax |
On or before later of: 3 years after
return filed or 2 years after tax paid |
6511(a) |
| If statute of limitations was extended
by consent: on or before 6 months after expiration of extended
period. |
6511(c)(2) |
| Filing suit for refund of
overpaid tax |
Not before: 6 months from date of filing
refund claim (with no response from IRS) or date of notice of
disallowance. |
6532(a)(1) |
| Not after: 2 years from date notice of
disallowance issued or 2 years from date statutory notice of
disallowance was waived. |
6532(a)(3) |