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CPA/REG/IRS Procedures & Appeals

IRS Procedures & Appeals

Audits, the appeals process, statutes of limitation, and where tax disputes get litigated.

Medium 50 minArea I: Ethics, Professional Responsibilities & Federal Tax Procedures

Statutes of limitation

SituationAssessment period
General rule3 years from the later of the due date or the filing date
Omission of more than 25% of gross income6 years
Fraudulent return or no return filedUnlimited
Refund claim by taxpayerLater of 3 years from filing or 2 years from payment

The dispute path

  1. Examination — correspondence, office, or field audit
  2. 30-day letter — proposes adjustments and offers an Appeals conference
  3. Appeals Office — independent; settles based on hazards of litigation
  4. 90-day letter (statutory notice of deficiency) — the "ticket to Tax Court"
  5. Litigation

IMPORTANT: The U.S. Tax Court is the only forum where the taxpayer can litigate without first paying the disputed tax. To sue in the U.S. District Court or the Court of Federal Claims, the taxpayer must pay first and sue for a refund. The District Court is also the only forum offering a jury trial.

Key taxpayer penalties

PenaltyAmount
Failure to file5% per month, max 25% (minimum applies if >60 days late)
Failure to pay0.5% per month, max 25%
Accuracy-related (negligence or substantial understatement)20% of the underpayment
Civil fraud75% of the underpayment attributable to fraud

When failure-to-file and failure-to-pay both apply in the same month, the failure-to-file penalty is reduced by the failure-to-pay penalty.

EXAM TIP: "Substantial understatement" for an individual generally means the understatement exceeds the greater of 10% of the tax required to be shown or $5,000. Reasonable cause and good faith is a defense to accuracy-related penalties — but never to fraud.