DETERMINING WHEN A RETURN IS SUFFICIENT TO START THE STATUE OF LIMITATIONS. (rev’d 090721).

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Determining the Statute of Limitations: While the statute of limitations for examination is generally three years from the date a return is filed, the statue can be automatically extended, can be voluntarily extended, or tolled under various provisions provided in the code, regulations, rulings and court cases. Your job is to advise your clients as to the applicable statute of limitations based on the fact pattern to be provided to you below. Remember: the date a return is deemed filed is a question of both fact and law.

It is October 1, 2021. The clients have not filed their joint current year’s tax return. No extension has been filed. Your clients have filed timely in the past and there is no reason to suspect that there is unreported income (once the return is filed). They live in Florida and have been unaffected by a hurricane or other severe weather event. Your team must write a memorandum to the client explaining when a tax return filing will be deemed sufficient to start the statute of limitations for both examination and assessment purposes. In addition, the clients have asked if they should file a joint tax return under the facts above. You should cite, as appropriate, the code, regulations, rulings, court cases… etc. Make sure that the memo addresses all the following questions for both types of returns:

• What are the elements of a complete return?
• What is the general limitation on assessment?
• What are the exceptions to the general statute of limitations on Assessment?
• When is a return deemed sufficient to start the statute of limitations?
• What happens if IRS files a return on behalf of taxpayer?
• Under what circumstances will a statute not start?
• If the statute is not deemed to start, because of not being deemed to be a complete return, what curative actions may be necessary in order to start the statute of limitations?
• When is the statutes of limitations tolled from running? For how long?