The Statute of Limitations on Assessment – Tips and Traps of Dealing with the IRS

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The statute of limitations on assessment is one of the most powerful—and often misunderstood—procedural tools in federal tax practice. While the IRS generally has three years to assess additional tax, numerous exceptions and procedural nuances can dramatically extend or shorten this period. Understanding these rules is critical when managing audits, evaluating IRS actions, and deciding whether strategic decisions—such as extending the statute—serve a client’s best interests.

This course provides a practical, step-by-step examination of the IRS assessment process and the statute of limitations rules that govern it. Taught by former IRS Chief Counsel attorney Robert Misey, the program explains how assessment timing works, when the general three-year rule applies, and how various statutory exceptions can alter the assessment window. Participants will learn how the IRS tracks deadlines, issues notices, and uses procedural tools that impact taxpayer rights.

Designed for tax professionals involved in audit defense and controversy work, this course equips attendees with the knowledge needed to evaluate IRS actions, protect clients’ procedural rights, and confidently navigate one of the most consequential areas of IRS practice.

Who Should Attend
This course is designed for tax professionals who represent clients before the IRS and must understand procedural timing rules that can significantly affect audit outcomes.

Topics Covered

• Overview of IRS assessment procedures
• Notices of Deficiency and last known address rules
• General three-year statute of limitations on assessment
• Exceptions to the statute of limitations on assessment
• Statute of limitations for refund claims
• Mitigation provisions affecting expired statutes
• Strategic considerations when dealing with IRS timing issues

Learning Objectives

• Explain the timing and procedures involved in the IRS assessment process
• Apply the general three-year statute of limitations on assessment
• Identify statutory exceptions that extend or suspend the assessment period
• Evaluate whether consenting to extend the statute of limitations is advantageous
• Assess IRS examination timing to improve representation and audit strategy

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None