Neal CA

[neallove]

Client received a bill from IRS in 2010 for 2006 gambling income not reported. He paid the bill in 2010.

Does this now extend the statute of limitations?

[kpangelinan]

Client received a bill from IRS in 2010 for 2006 gambling income not reported. He paid the bill in 2010.

Does this now extend the statute of limitations?

Did he file for 2006 or file late?....that would be the only way I think this could happen. If he didn't file, then there is no statute until he files or IRS files an SFR. If he filed in 2009, then the 3 year amendment statute starts then, not the tax year.

[neallove]

neal

He filed a return in 2006 and paid the tax. He received the IRS notice in 2010 and they assessed additonal tax for 2006.

[kpangelinan]

He filed a return in 2006 and paid the tax. He received the IRS notice in 2010 and they assessed additonal tax for 2006.

You mean in 2007 for 2006? He couldn't have filed a return for 2006 the same year. The IRS had until April 15th of 2010 to audit the return (assuming he filed on or before April 15th 2007). If that's the case, then the taxpayer would have had the opportunity to correspond with a revenue officer or through mail correspondence to adjust the return. If he passed any deadlines to respond, then he's out of luck.

Need more info.