Beyond the Three-Year Clock: Navigating the Exceptions to the IRS Assessment Statute of Limitations

The three-year statute of limitations on IRS assessment is one of the most useful tools available to a taxpayer’s representative — but only when it has actually run. The Internal Revenue Code includes more than a dozen exceptions that can extend the assessment period, and several can eliminate the limitations period entirely.

This program provides a practitioner-focused overview of IRC §6501 and the circumstances under which the ordinary three-year assessment period may be extended, suspended, or never begin. Topics include fraud and unfiled returns, agreed extensions under Form 872, substantial omissions of income, unreported foreign assets and gifts, undisclosed listed transactions, and other reporting failures that can leave a tax year open to assessment.

The program will also address common practitioner traps, including the distinction between FBAR reporting failures and the Internal Revenue Code’s foreign-asset disclosure requirements.

Attendees will leave with a practical framework for evaluating whether a client’s assessment period has closed and a better understanding of the disclosure standards governing several significant exceptions.

About the Presenter

Matt Eddleman, EA, is Tax Director at Frost Law. He brings more than two decades of experience in tax controversy, accounting, financial planning, and small business management. His work with individuals and business owners gives him a broad perspective on complex tax matters and the planning opportunities available to taxpayers.