REG – Statue of Limitation Fraud/Criminial

CPA Exam Forum The Forum REG Review REG – Statue of Limitation Fraud/Criminial

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    Soproudofmyself
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    This is confusing me…

    There is no statue of limitation on fraudulent tax returns and the IRS has the burden of proof –> ok makes sense.

    The statue of limitation on just regular assessment of taxes is 3 years –> ok makes sense.

    The statue of limitation is 6 years if you underreport gross income by more than 25%…..

    The statue of limitation is 6 years if you willfully attempted to evade or defeat any tax, willfully failing to pay any tax, not filing any tax return, etc.

    How are the above 2 examples claiming to have a 6 year statue of limitation not falling within the fraudulent tax returns? I would have grouped these situations in fraudulent….especially willfuly attempting to evade or defeat any tax???

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