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
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.
Outline
- Statutes of limitations: an overview
- Ten-year collections statute
- Three-year assessment statute
- Statute for refund claims
- Statutory notices of deficiency
- Fraud
- Voluntary and non-voluntary statute suspensions
- Ensuring the statute runs: case studies
- Recent cases
- Right to finality
Benefits
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
Faculty
Joel N. Crouch
Managing Partner
Meadows Collier Reed Cousins Crouch & Ungerman
Mr. Crouch specializes in civil and criminal tax controversies involving sophisticated and... | Read More
Mr. Crouch specializes in civil and criminal tax controversies involving sophisticated and complex legal and tax issues, both domestic and international. He has extensive experience in resolving tax matters at all stages of a tax dispute including IRS examinations, administrative appeals, and litigation in the U.S. Tax Court, the U.S. Court of Federal Claims and U.S. District Courts, and before the United States Supreme Court. He is a frequent speaker on both substantive and procedural tax issues for both legal and accounting professionals.
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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
Mr. Freeman is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. He represents clients in litigation and disputes, with a particular focus on federal and state tax controversies. Mr. Freeman handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges. He also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements. He serves on the law school faculty at SMU’s Dedman School of Law, where he teaches a course in the law of federal income taxation, and he is a frequent public speaker across the country, presenting and educating on various legal topics.
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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
Mr. van Dyk has extensive experience in the tax field. He has represented hundreds of taxpayers in tax court, audit, as well as collection proceedings. His areas of expertise include all issues relating to individual and corporate taxpayers, audits, audit appeals proceedings and collection due process hearings, as well as litigation in the United States Tax Court.
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