Determining the Statute of Limitations:??While the statute of limitations for examination is generally three years from the date a
Determining the Statute of Limitations: While the statute of limitations for examination is generally three years from the date a return is filed, the statue can be automatically extended, can be voluntarily extended, or tolled under various provisions provided in the code, regulations, rulings and court cases. Your job is to advise your clients as to the applicable statute of limitations based on the fact pattern to be provided to you below. Remember: the date a return is deemed filed is a question of both fact and law.
It is October 1, 2021. The clients have not filed their joint current year’s tax return. No extension has been filed. Your clients have filed timely in the past and there is no reason to suspect that there is unreported income (once the return is filed). They live in Florida and have been unaffected by a hurricane or other severe weather event. Your team must write a memorandum to the client explaining when a tax return filing will be deemed sufficient to start the statute of limitations for both examination and assessment purposes. In addition, the clients have asked if they should file a joint tax return under the facts above. You should cite, as appropriate, the code, regulations, rulings, court cases… etc. Make sure that the memo addresses all the following questions for both types of returns:
1. What are the exceptions to the general statute of limitations on Assessment?
2. When is a return deemed sufficient to start the statute of limitations?
TEAM ASSIGNMENT 1: DETERMINING WHEN A RETURN IS SUFFICIENT TO START THE STATUE OF LIMITATIONS. (rev’d 090721).
Determining the Statute of Limitations: While the statute of limitations for examination is generally three years from the date a return is filed, the statue can be automatically extended, can be voluntarily extended, or tolled under various provisions provided in the code, regulations, rulings and court cases. Your job is to advise your clients as to the applicable statute of limitations based on the fact pattern to be provided to you below. Remember: the date a return is deemed filed is a question of both fact and law.
It is October 1, 2021. The clients have not filed their joint current year’s tax return. No extension has been filed. Your clients have filed timely in the past and there is no reason to suspect that there is unreported income (once the return is filed). They live in Florida and have been unaffected by a hurricane or other severe weather event. Your team must write a memorandum to the client explaining when a tax return filing will be deemed sufficient to start the statute of limitations for both examination and assessment purposes. In addition, the clients have asked if they should file a joint tax return under the facts above. You should cite, as appropriate, the code, regulations, rulings, court cases… etc. Make sure that the memo addresses all the following questions for both types of returns:
1. What are the exceptions to the general statute of limitations on Assessment?
2. When is a return deemed sufficient to start the statute of limitations?
Collepals.com Plagiarism Free Papers
Are you looking for custom essay writing service or even dissertation writing services? Just request for our write my paper service, and we'll match you with the best essay writer in your subject! With an exceptional team of professional academic experts in a wide range of subjects, we can guarantee you an unrivaled quality of custom-written papers.
Get ZERO PLAGIARISM, HUMAN WRITTEN ESSAYS
Why Hire Collepals.com writers to do your paper?
Quality- We are experienced and have access to ample research materials.
We write plagiarism Free Content
Confidential- We never share or sell your personal information to third parties.
Support-Chat with us today! We are always waiting to answer all your questions.
