- Federal Taxes
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- International Tax
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- U.S. Citizens and Permanent Residents Living Abroad
- Expatriation
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- Foreign Currency Transactions
- Inbound Transactions
- Foreign Persons and U.S. Investments
- Transfer Pricing
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Tax Controversy Services
- Negotiation of Payments or Settlements
- Levy and Lien
- Audits
- Audit Reconsideration
- Filing of Delinquent Tax Returns
- Employment Tax issues and the Trust Fund Recover Penalty
- Penalty Abatement
- Interest Abatement
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- Statute of Limitations (SOL)
- Frivolous Tax Positions
- Appeals and Collection Due Process Hearings
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Services
Tax Controversy Services
Statute of Limitations (SOL)
The IRS has specific statutes of limitations (SOL) on tax assessments based on certain criteria. The 3 year SOL for which the IRS can assess taxes is based on the date the return is supposed to be filed, not including extensions. The 6 year SOL applies when a tax return shows a substantial understatement of gross income (25%+). However, the Indefinite statute, one that does not expire, will apply if the taxpayer 1) files a false or fraudulent return, 2) Willfully attempts to evade tax, or 3) Fails to file a required return. Although the IRS has 10 years to collect due taxes, it can be extended for a number of reasons. The Esquire Group tax professionals are ready to evaluate your circumstances and advise you as to what course of action to take to head off future problems if you demonstrate discrepancies on past tax returns and if there are any circumstances that might cause the IRS to consider extending the 10 year SOL.
