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specifically, section 6501(c)(4) provides that, where the
Internal Revenue Service (IRS) and the taxpayer have consented in
writing, the assessment period is extended. The accompanying
regulations state that the extension of the assessment period
"[becomes] effective when the agreement has been executed by both
parties." Sec. 301.6501(c)-1(d), Proced. & Admin. Regs.
1(...continued)
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) or, if the tax is payable by stamp, at any time
after such tax became due and before the expiration of 3
years after the date on which any part of such tax was paid,
and no proceeding in court without assessment for the
collection of such tax shall be begun after the expiration
of such period.
* * * * * * *
(c) Exceptions.--
* * * * * * *
(4) Extension by agreement.--Where, before the
expiration of the time prescribed in this section for
the assessment of any tax imposed by this title, except
the estate tax provided in chapter 11, both the
Secretary and the taxpayer have consented in writing to
its assessment after such time, the tax may be assessed
at any time prior to the expiration of the period
agreed upon. The period so agreed upon may be extended
by subsequent agreements in writing made before the
expiration of the period previously agreed upon.
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