- 12 - As applicable herein, in the case of FICA taxes reportable on Form 941, the return is due on or before the last day of the first calendar month following the calendar quarter for which the return is required. See sec. 6071(a); sec. 31.6071(a)-1(a), Employment Tax Regs.; see also sec. 31.6011(a)-1, Employment Tax Regs., regarding the requirement for filing such a return. However, if a return for a calendar quarter is filed before April 15 of the following calendar year, the return shall be deemed to have been filed on April 15 of the following calendar year. See sec. 6501(b)(2). Also relevant to our discussion is section 6501(c)(4), which provides an exception to the general rule of section 6501(a) prescribing a 3-year period of limitations. Thus, as relevant herein, section 6501(c)(4) provides that where, before the expiration of the period of limitations otherwise applicable to the assessment of a tax, both the taxpayer and the Commissioner have consented in writing to its assessment after such time, the tax may be assessed at any time before the expiration of the period agreed upon. In addition, the period so agreed upon may be further extended by subsequent agreements made in writing before the expiration of the period previously agreed upon. See sec. 6501(c)(4). Further relevant to our discussion is section 6503(a)(1). That section, as applicable to the present action by virtue ofPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011