I.R.C. § 6501

IRS Declines To Extend Time To Make Late Success-Based Fee Elections

Recently, the IRS Office of Chief Counsel held, in a private letter ruling, that it could not grant a taxpayer’s request for an extension of time to file a safe harbor election under Rev. Proc. 2011-29. This election is related to the treatment of success-based fees incurred in the process of pursuing certain transactions. Under the safe harbor election described in Rev. Proc. 2011-29, the election must be made on an original tax return. The election applies to covered transactions under Treas. Reg. Sec. 1.263(a)-5(e)(3).

You’ve filed your tax return, how long does the IRS have to audit you?

You’ve filed your tax return, how long does the IRS have to audit you?You’ve filed all of your tax returns, and because of your level of income you find yourself in the class of taxpayers whose return is more likely to trigger an IRS audit. So you wonder, how long does the IRS now have to audit you?

Due to disclosure requirements, the IRS makes contact with a taxpayer selected for an audit by telephone or mail only.  When returns are filed, they are compared against norms for similar returns. These norms are developed from audits of a statistically valid random sample of returns, selected as part of the National Research Program conducted by the IRS to update return selection information.

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