IRM Interim Guidance: Definition of an Imminent Assessment Statute Expiration Date (IRC §6501)

Revision to Internal Revenue Manual 5.7.3.2.1, Monitoring TFRP Cases, that would clarify the definition of an imminent statute case in trust fund recovery penalty cases, released December 20. The IRM update will include specific language defining imminent statute cases as those with less than one year remaining on the assessment statute expiration date (ASED), the IRS provided. Effective December 2, 2021. [SBSE-05-1221-0062 (Dec. 2, 2021)]

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