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Six-Year Statute of Limitations for Tax Assessments Upheld

Posted by Kamyar Mehdiyoun, Esq. | May 05, 2023

The U.S. Court of Appeals for the Eighth Circuit ruled in June 2015 that the IRS properly applied the 6-year statute of limitations (instead of the shorter 3-year) because the taxpayer had omitted more than 25% of his gross income from his return. The taxpayer claimed that since the IRS had found out about the omission within 3 years from the filing date, the shorter period of limitations applied. Taxpayer had filed his 2003 income in 2004. The IRS had learned about the omission in 2007 but had delayed sending a notice of deficiency for 2003 tax liability until 2010 which exceeded the 3-year period but was within the statutory 6-year period which is applicable when the amount of unreported income exceeds 25% of the taxpayer's income. The Eighth Circuit upheld the U.S. Tax Court's ruling in favor of the IRS. (Heckman v. Commissioner of Internal Revenue, U.S. Court of Appeals, Eighth Circuit, June 2015, No. 14-3251)

About the Author

Kamyar Mehdiyoun, Esq.

Kamyar Mehdiyoun, holds a Master of Law (LL.M.) degree in taxation from Georgetown University Law Center and focuses his practice on tax law. In 2003, he received the Award for Excellence in Tax Practice and Procedure from Georgetown. He also holds a Certificate in Employee Be...

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