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Tolling Tax Statutes of Limitations: Collections, Refund Claims, IRS Audits, and the Right to Finality

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, January 28, 2021

Recorded event now available

or call 1-800-926-7926

This course will explain the critical tax statutes of limitations relative to filing income tax returns, filing refund claims, and IRS debt collections. There are many times practitioners welcome the tolling of a statute. Our experts will explain what does and does not extend these statutes and basic taxpayer finality rights included in the Taxpayer Bill of Rights.


There are many tax statutes of limitations, and although many work against the taxpayer, many can work in the taxpayer's favor. Included as No. Six in the Taxpayer's Bill of Rights is the Right to Finality. As explained by the IRS, "Taxpayers have the right to know the maximum amount of time they have to challenge the IRS's position as well as the maximum amount of time the IRS has to audit a particular tax year or collect a tax debt. Taxpayers have the right to know when the IRS has finished an audit."

A taxpayer's delinquent tax bill could be canceled if the 10-year statute on collections passes without the IRS collecting the balance due. Most are aware that the IRS generally has three years from the date a taxpayer files his return (or original due date) to assess the additional tax due. More confusing is the refund claim statute, which says you must file a claim within three years of the filing date or two years from the date you paid tax (whichever is later) to receive a refund.

Filing false or fraudulent tax returns can extend relative statutes. Tax practitioners must understand the maximum amount of time the IRS has to assess and collect tax and the maximum amount of time taxpayers have to challenge an IRS position, as well as what extends these critical deadlines.

Listen as our panel of tax professionals outlines what tax preparers need to know about taxpayers' rights to finality and the many tax statutes of limitations.



  1. Statutes of limitations: an overview
  2. Ten-year collections statute
  3. Three-year assessment statute
  4. Statute for refund claims
  5. Statutory notices of deficiency
  6. Fraud
  7. Voluntary and non-voluntary statute suspensions
  8. Ensuring the statute runs: case studies
  9. Recent cases
  10. Right to finality


The panel will explain these and other critical issues:

  • Specific situations where practitioners may want to ensure a statute tolls
  • When, and when not, to voluntarily extend the statute of limitations
  • How the 10-year collection statute can work in a taxpayer's favor
  • The timeframe for filing a refund claim
  • How taxpayers' right to finality impacts an IRS audit


Crouch, Joel
Joel N. Crouch

Managing Partner
Meadows Collier Reed Cousins Crouch & Ungerman

Mr. Crouch specializ​es in civil and criminal tax controversies ​involv​ing sophisticated and...  |  Read More

Freeman, Jason
Jason B. Freeman, J.D., CPA

Founder and Managing Member
Freeman Law

Mr. Freeman is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. He represents clients in...  |  Read More

van Dyk, Arnold
Arnold van Dyk

Director of Tax Services, TaxAudit
The Law Offices of Arnold van Dyk

Mr. van Dyk has extensive experience in the tax field. He has represented hundreds of taxpayers in tax court, audit, as...  |  Read More

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