. STATUTE OF LIMITATIONS 8.10 Under the Code, a Trust Fund Recovery Penalty must be assessed within three years of the April 15th following the year during which the quarterly liabilities arose IRC 6501 (a), (b)(2)]. For example, The penalty with respect to liabilities arising during 1985 must be assessed on or before April 15, 1989. If the return is filed later than the April 15th following the year during which the liability arose, the statutory period for assessment is three years from the date of filing.
Posted on: Sat, 25 Jan 2014 12:39:21 +0000
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