Statutes of Limitations

From the Government’s perspective, statutes of limitation restrict the taxpayer’s right to claim a refund of
overpaid tax or initiate litigation to obtain a refund. From the taxpayer’s perspective, statutes of limitation
prevent the IRS from collecting a deficiency in tax or beginning a civil or criminal case. In short, statutes of
limitation provide a date of finality after which actions taken by the IRS or the taxpayer cannot be disturbed by

the other party

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Audit Reconsideration

An Audit Reconsideration is the process the IRS uses to reevaluate the results of a prior audit where additional tax was assessed and remains unpaid, or a tax credit was reversed. If the taxpayer disagrees with the original determination he/she must provide information that was not previously considered during the original examination. It is also the process the IRS uses when the taxpayer contests a Substitute for Return (SFR) determination by filing an original delinquent return.

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