MVLS/Frost Law: Beyond the Three-Year Clock - Navigating the Exceptions to the IRS Assessment Statute of Limitations

The three-year statute of limitations on IRS assessment gives taxpayer representatives a valuable tool, but only when the clock has actually run out. The Internal Revenue Code contains more than a dozen exceptions that extend this period, and several eliminate it entirely. Many practitioners discover this only after the fact.

Matt Eddleman, EA, presents a practitioner-focused survey of IRC §6501 and the circumstances that extend, suspend, or prevent the ordinary three-year assessment period from starting at all. The session covers fraud and unfiled returns, agreed extensions under Form 872, and the six-year rule for substantial omissions of income, including the unresolved treatment of overstated basis. It also addresses unreported foreign assets and gifts, undisclosed listed transactions, and reporting failures that can leave an entire tax year open to assessment.

Eddleman will highlight a common practitioner trap – the confusion between FBAR reporting failures and the Internal Revenue Code's own foreign-asset disclosure rules. Attendees will leave with a working framework for evaluating whether a client's assessment period has actually closed, along with the disclosure standards that determine whether the most significant exceptions apply.