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Statute of Limitations › Tax Returns › Income Taxes

Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period... more +
Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period usually commencing from the date of the wrong or injury or the discovery of the wrong or injury. Except for under a limited set of circumstances, if an individual does not file a suit within the specified time period, the law bars them from ever suing on that claim. less -
Smith Anderson

Franchise Tax Refund Opportunity

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Corporations subject to North Carolina’s franchise tax have an opportunity to seek refunds of their 2021 and 2022 franchise taxes but should act promptly to preserve their rights....more

Allen Barron, Inc.

Tax Updates and Information for US Expatriates

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US tax filing is underway, and as we approach the April 15 deadline we would like to offer additional tax updates and information for US expatriates. The first and most important thing for US expatriates to know about taxes...more

DarrowEverett LLP

IRS Response to Israel’s Declaration of War: Relief to Impacted Taxpayers, But Extensions Granted to Its Enforcement Arm

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In IRS Notice 2023-71 (the “Notice”), the Internal Revenue Service (“IRS”) granted a postponement until October 7, 2024 for various time-sensitive filing and payment deadlines for taxpayers affected by the terrorist attacks...more

Freeman Law

Tax Court in Brief | Fairbank v. Comm’r | Reporting Obligations for Foreign Trust Income and Ownership; Statute of Limitations

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Summary:  At its core, this 31-page opinion regards married U.S. citizen taxpayers, Leigh Fairbank (Leigh) and Barbara Fairbank (Barbara), challenge to deficiency notices issued for the tax years in issue (2003 through 2009...more

Blank Rome LLP

State Barred by Statute of Limitations from Recovering an Erroneous Refund Payment

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The New Jersey Tax Court recently granted a pro se taxpayer’s motion for summary judgment and ruled that the Division of Taxation was barred by the statute of limitations from recovering an erroneous income tax refund payment...more

Freeman Law

Protective Refund Claims: Preserving the Right to a Tax Refund

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When is a protective refund claim available?  Taxpayers often face uncertain outcomes in litigation or business transactions, giving rise to contingent tax refund claims.  For example, if a pending lawsuit ends in a favorable...more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

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In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

Freeman Law

The Tax Court in Brief - June 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of June 14 – June 18, 2021 - Bell Capital Management, Inc....more

Holland & Knight LLP

When Is a Tax Return "Filed"?

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In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

Freeman Law

Everything That You Need To Know About International Tax Penalties

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International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more

Foster Garvey PC

The IRS Will Put the American People First — No, Really (But Only for a Limited Time)

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Wednesday, March 25th, in the wake of the recent decision by the Internal Revenue Service (“IRS”) to extend the income tax filing and payment deadlines to July 15, 2020, it announced a new taxpayer-friendly program called the...more

Burr & Forman

IRS Announces New “People First Initiative” Suspending Many Important Federal Tax Compliance Dates and Certain Tax Collection...

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March 25, 2020 – The IRS announced a major suspension of many “tax compliance” dates and tax collection measures. Published in IRS Information Release 2020-59 as the “People First Initiative”, the IRS announced that it is...more

Fox Rothschild LLP

Pennsylvania Supreme Court: Corporate Tax Refund Claim Must Be Filed Within Three Years Of Original Tax Return Due Date

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In Mission Funding Alpha, the Pennsylvania Supreme Court recently held that the statute of limitations for a corporation to file a refund claim in Pennsylvania begins to run when the corporate tax return is due, not when the...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 7, Issue 8

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ALJ holds that a Retailer Must File on a Combined Basis with a Related Intellectual Property Licensing Company - A New York State Administrative Law Judge has held that a retailer must file combined corporate franchise...more

McDermott Will & Emery

Court of Federal Claims Rules Adviser Fraud Does Not Extend Three-Year Statute of Limitations Period

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The U.S. Court of Federal Claims recently held that third-party fraud committed on a partnership’s tax return did not extend the three-year statute of limitations period for assessment of income taxes, a decision that...more

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