The IRS had no deadline to assess additional taxes on a filer when, without her knowledge, her tax return preparer had committed fraud against the agency in the 1990s, the Third Circuit ruled Monday.
The federal government normally has a three-year deadline to audit a tax return and make assessments, but that deadline is suspended under IRC Section 6501(c)(1) when the return is false or fraudulent with an intent to evade tax. But that statute is “agnostic” as to who exactly is trying to evade tax, be it the taxpayer or some other party, Judge
Stephanie ...