In tax controversy and litigation matters, sometimes procedure trumps the merits. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS ...

The article explains a legal split on whether the IRS can extend the tax assessment period based on a third party’s fraudulent intent. The Third Circuit in Murrin (2025) ruled it can, while the ...

Forbes contributors publish independent expert analyses and insights. Ashley L. Case, J.D., LL.M., writes about tax and estate planning. The Internal Revenue Code Section 6501 sets the framework for ...

As we discussed a few weeks ago,[i] the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection ...

IRS has a 10-year window to collect back taxes – but for many Americans, that doesn’t mean the debt simply disappears. The IRS Collection Statute Expiration Date (CSED) generally gives the government ...