In general the Internal Revenue Code provides that no action may be maintained more than six years after the commission of a criminal tax violation.
However, the Court has ruled that the statute does not necessarily begin when the tax return was filed or should have been filed.
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Court Finds That the Statute of Limitations in a Section 7202 Tax Case Begins When Willfulness Arises.
Failure to Pay Over Tax Does Not Require Proof of Ability to Pay
Written by on in Tax Fraud Report.
There is No Requirement That The Government Prove a Taxpayer Had Funds to Pay Tax to Obtain a Conviction Pursuant to Section 7202. Further, the Statute of Limitations for an Offense Under Section7202 is Six Years.