SALT LAKE CITY, UTAH:
Seaview Trading vs Commissioner, 9th Circuit Decision:
In Seaview Trading vs Commissioner, the 9th Circuit found in favor of the IRS and stated in part that providing a delinquent return to the auditor or office of chief counsel is not “Filing” for purposes of starting the three year ASED for audit/adjustment. This is a statute of limitation.
What this means is that a taxpayer can provide a copy of their tax return to an auditor but that same tax return will have to actually be filed with the applicable service center to be considered filed and to start the three year audit statute running.
Tax problems are legal problems, and we solve both. If you or someone you know has an issue with paying their federal taxes or state taxes and needs help to end their IRS nightmare, please contact us by either phone at (801) 323-2112 or email at: kbrown@strongandhanni.com or go to my personal webpage at: https://strongandhanni.com/attorneys/attorney-kent-brown/
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