Tax Court Upholds Indefinite IRS Assessment Window in Fraud Case

The IRS determined deficiencies against a taxpayer on time because the three-year statute of limitations for assessment is waived when the return at issue contains false or fraudulent information, the US Tax Court said on Wednesday, while declining to overturn established precedent.

Stephanie Murrin relied on tax return preparer Duane Howell from 1993 to 1999 to prepare her federal income tax returns, as well as the returns for two partnerships in which she was a general partner. Though the Murrins didn’t submit false information or intend to evade taxes, Howell did, triggering IRC Section 6501(c) to remove the time limit ...