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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Introduction
The typical small business owner or professional walks into our office owing delinquent taxes for a variety of different years. Often, the liabilities are a mixture of unpaid personal income taxes, including penalties and interest, and trust fund recovery penalties, assessed against the client in connection with the failure of his or her business to pay federal income taxes, Social Security and Medicare taxes withheld from its employees? wages. A number of solutions may be available to solve the problems, and selecting the best strategy will often depend on the various dates that the taxpayer's tax returns were due, when they were filed and when the delinquent taxes in question were assessed.
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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