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7/27/2012 1:57:26 PM
 
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Section 5: OPA Board Subject: IRS Beach Parking Matter Msg# 838042
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Norm
As I recall the normal statute of limitations is three years from the date the organizations's tax return is filed. I know of no seven year term. There is no statute of limitation for fraud., but there was no fraud alleged in the OPA filing... in fact, the IRS did not even levy a penalty for carelessness. Calculation of the amount due is very straightforward. Hope this helps. Jeff Knepper |
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For reference, the above message is a reply to a message where: Joe, That is good news. The multi-year appeals process has resulted in several of the years since FY 2004 no longer being subject to taxes because the period for assessing a federal or state deficiency has expired under the statute of limitations. This is the reason the ultimately determined Estimated Liability and recorded expense are substantially less than the amount of potential exposure previously communicated. Can anyone explain this to me chronologically? I'm not positive, but I believe the IRS can challange a mathamatical error for three years, a filing error for seven years and fraud forever. I'm having difficulty equating the statue of limitations to our specific situation. The Estimated Liability has been determined to be $340,000 at April 30, 2012 for federal and Maryland taxes and interest. This amount, combined with the approximately $119,000 previously paid for federal taxes and interest for FY 2003 and FY 2004, results in an expense of $459,000, which will be recorded in the audited FY 2012 financial statements. Is this OPA's opinion or has the IRS accepted this? Norm Norm |
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