Summons on Swiss Bank Paused IRS Deadline to Issue Tax Penalties

The IRS was on time asserting more than $500,000 in penalties against a couple for not reporting about $6.79 million in offshore income because the statute of limitations was suspended when the agency served a John Doe summons on a Swiss bank.

Linda and Johannes Lamprecht urged the US Court of Appeals for the D.C. Circuit to toss the penalties because the IRS issued their notice in 2015, which they argued was after the government’s six-year deadline for alleged deficiencies from 2006 and 2007. But that deadline was extended by the nature of the John Doe summons the government issued, ...