For Whom the Tax Tolls: Significant Events That Extend IRS Collection Rights

Published in Tax Practice & Procedure - October/November 2004

By Michael S. Fried and Zachary S. Fried

Michael and Zachary Fried outline the events that can extend or toll statutes of limitation on IRS collection actions and analyze the holding of the U.S. Supreme Court in C.P. Young and subsequent IRS pronouncements.

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Michael S. Fried is a Member of the law firm of Hodes, Ulman, Pessin, & Katz, P.A., in Bethesda, Maryland, and focuses his practice on IRS tax controversy matters and the resolution of delinquent tax liabilities.

Zachary S. Fried is a second-year law student at George Washington University Law School in Washington, D.C.

Introduction
Statute of Limitation on Collection
Discharge of Taxes in Bankruptcy
Hypothetical Client
Collection Statute Expiration
Bankruptcy Solutions and Tolling Issues
1998, 1999 and 2000 Tax Liabilities
1997 Tax Liability
Two Hundred and Forty?Day Assessment Period
Application of Three-Year Look Back Rule and Two-Year Filing Rule to 1997 Tax
LTR 200404049
Application to 1997 Tax Liability
1987 to 1996 Tax Liabilities
Conclusion
Endnotes & Sources