V. Statute of Limitations Defense
Perhaps the most important affirmative defense in tax cases is the statute of limitations. Section 6531 controls the statute of limitations periods for most criminal tax offenses. Under section 6531, the general rule is that the statute of limitations for criminal tax offenses is three years. However, the exceptions to the three-year rule essentially swallow up the general rule.
The CTM includes a helpful table that sets forth the limitations periods for common tax offenses: Read More
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