Medium1 markMultiple Choice
Area 1: Ethics & ProceduresTax ProceduresStatute of Limitations

CPA · Question 05 · Area 1: Ethics & Procedures

Taxpayer A filed their Year 1 tax return on April 15, Year 2. The return omitted ,000 of gross income, which exceeded 25% of the gross income stated on the return. No fraud was involved. What is the latest date the IRS can assess additional tax?

Answer options:

A.

April 15, Year 5

B.

April 15, Year 8

C.

April 15, Year 9

D.

There is no statute of limitations.

How to approach this question

Determine the applicable statute: Standard (3 years), Substantial Omission >25% (6 years), or Fraud/No Filing (Unlimited). Calculate from the later of the due date or filing date.

Full Answer

B.April 15, Year 8✓ Correct
IRC §6501(e) provides a 6-year statute of limitations if the taxpayer omits gross income in excess of 25% of the gross income stated on the return.

Common mistakes

Applying the 3-year rule or thinking it's unlimited (fraud).

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