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Trucking Associations, Inc., 310 U.S. 534, 543-544 (1940).
As provided in the Code:
SEC. 6501. LIMITATIONS ON ASSESSMENT AND COLLECTION.
(a) General Rule.--Except as otherwise provided in
this section, the amount of any tax imposed by this
title shall be assessed within 3 years after the return
was filed (whether or not such return was filed on or
after the date prescribed) * * *
* * * * * * *
(c) Exceptions.--
* * * * * * *
(3) No return.--In the case of failure
to file a return, the tax may be assessed, or
a proceeding in court for the collection of
such tax may be begun without assessment, at
any time.
As stated in the regulations:
� 1.6012-1. Individuals required to make returns of
income.-- * * *
* * * * * * *
(b) Return of nonresident alien individual--* * *
* * * * * * *
(2) Exceptions.--(i) Return not required
when tax is fully paid at source. A
nonresident alien individual * * * who at no
time during the taxable year is engaged in a
trade or business in the United States is not
required to make a return for the taxable
year if his tax liability for the taxable
year is fully satisfied by the withholding of
tax at source under chapter 3 of the Code.
This subdivision does not apply to * * * a
nonresident alien individual making a claim
under � 301.6402-3 of this chapter (Procedure
and Administration Regulations) for the
refund of an overpayment of tax for the
taxable year. * * *
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