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Statute Of Limitations

  • Section 6501(a) - The general statute of limitation within which the IRS must assess is 3 years from the due date of the return or the date the return is actually filed (state of California is 4 years);
  • Section 6501(e) – Contains the 6-year statute for the underreporting of income of more than 25%
  • Section 6501(c)(1), (2), & (3) provides for an unlimited statute for fraud, attempt to evade and failure to file.


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