Reprinted with permission from Taxes, June 2016

Tax evaders have never enjoyed repose from statutes of limitation in federal tax cases. During the 19th century, the Supreme Court twice removed limitations from federal tax collectors where the government proved that their delinquent assessments were due to fraud on the part of taxpayers or their agents. Congress first codified this principle in Section 250(d) of the Revenue Act of 1918, which has survived through codification in Code Sec. 6501(c)(1). Read More

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