We represent clients from all U.S. and International locations regarding Federal Tax and California Issues.
Factors agents are instructed to consider in determining whether shorter or longer periods should be enforced are:
Ordinarily, an IRS group manager’s approval is required for all enforcement activity that is less than or exceeds the six-year period. However, a group manager’s approval is not needed if the non-filer voluntarily files returns beyond the established enforcement period of six years.
Prior years beyond the six-year enforcement limit may still be required because of some pending IRS action. Those outstanding actions include balance due years or special monitoring activity. Lastly, when filing an Offer in Compromise after filing the delinquent returns, all of the delinquent tax returns are required to be filed in order to be eligible for an Offer in Compromise.