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
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