Wiley L. Barron, CPA, Ltd. - Page 13




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               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 of              






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