The following is an excerpt from:
"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
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1997 Tax Liability
Working backwards, we turned our attention to the dischargeability of the taxpayer's $100,000 1997 income tax liability. The 1997 tax return was file on October 15, 1998, the last available due date for filing, and related tax was assessed on November 30, 1998. All of these events occurred after, and were unaffected by, the client's previous bankruptcy case. However, assessment of the 1997 tax liability occurred before December 9, 1998, and the 1997 tax liability was included in Dr. Delinquent's offer in compromise. Did the offer in compromise toll any of the three bankruptcy discharge time periods for this tax year?
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- 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