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Sec. 6501(c) allows the IRS and a taxpayer to consent in writing to extend the statute of limitation to assess tax. Usually the Service makes the request to extend the limitation period because it cannot complete an examination within the normal three-year period for making an assessment against the taxpayer.
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.
As a general rule, the IRS must assess additional tax and propose penalties no later than 3 years after either a tax return is filed or the return's due date, whichever is later. IRC Section 6501. An assessment is the recording of the tax debt on the books of the IRS.
How far back can the IRS go to audit my return? Generally, the IRS can include returns filed within the last three years in an audit. If we identify a substantial error, we may add additional years. We usually don't go back more than the last six years.
Assessment Statute Expiration Date (ASED) The general rule is that an assessment of tax must be made within three years from the received date of an original tax return or three years from the due date of the original return, whichever is later.
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People also ask

When the IRS issues a Notice of Deficiency to the taxpayer, the SOL is suspended until either (1) the 90 days for filing a tax court petition have passed and no petition was filed, or (2) the taxpayer timely filed a petition with the tax court and the decision of the court is final.
The Notice of Deficiency IRS Letters 3219 and 531 (also referred to as 90-Day Letters), are a taxpayer's legal notice that the IRS is proposing a deficiency (balance due). This notice or letter may include additional topics that have not yet been covered here. Please check back frequently for updates.
You'll still have to pay interest on any tax not paid by the regular due date of your return. You can also receive an additional 4-month extension of time to file (or, a total of six months) if you file Form 4868 and check the box on line 8 to indicate that you need an additional 4 months to file your return.
Generally, under IRC § 6502, the IRS will have 10 years to collect a liability from the date of assessment. After this 10-year period or statute of limitations has expired, the IRS can no longer try and collect on an IRS balance due.
The overarching federal tax statute of limitations runs three years after you file your tax return. If your tax return is due April 15, but you file early, the statute runs exactly three years after the due date, not the filing date. If you get an extension to October 15, your three years runs from then.

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