Wednesday, June 4, 2008

OIC Statute of limitations

The statute of limitations on collection will be suspended while levy is prohibited:

(1) during the period the offer is pending;

(2) for 30 days immediately following rejection of the offer; and

(3) for any period when a timely filed appeal from the rejection is being considered by Appeals (Reg. §301.7122-1(i)(1)).

Although the IRS may continue to require, when appropriate, the extension of the statute of limitations, the IRS must notify the taxpayer of the taxpayer's right to:

(1) refuse to extend the limitations period, or

(2) limit the extension to particular issues and/or particular periods of time (Reg. §301.7122-1(i)(2)).

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