Form 872-B (Rev July 2003), (Fill-In Capable)-2025

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The open-ended consent may be used for cases placed in suspense, scheduled for appeals or other situations where it would be advantageous to both you and the Service to do so. Form 872-A, Special Consent to Extend the Time to Assess Tax, is used for agreeing to an open-ended assessment period.
Length of Extension Once the original date under the statute of limitations is extended by a signed consent, it may be further extended by the mutual agreement of the parties before the expiration date of the previous extension period. The fixed-date consent is used for most examination and appeal activities.
What is Form 872? Form 872 is a simple form invoice in which the Taxpayer agrees to extend the statute of limitations through the following year (usually), to allow the IRS sufficient time to work the case. They are commonplace in nearly all VDP cases.
If you request an Installment Agreement (IA), the time the request is pending pushes out, or suspends the running of, the initial ten-year collection period. An IA request is often pending until it can be reviewed, and an IA is established, or the request is withdrawn or rejected.
Interest and penalties may be added onto the original amount owed. However, certain events stop the 10-year statute of limitations from running, including filing for an appeal, filing for bankruptcy, litigation against the IRS, an offer in compromise, and a collection due process hearing.

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To be valid, the consent form evidencing the agreement to extend the period of time to assess tax must be executed by both the taxpayer and the IRS before the statutory period for assessment expires.

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