Insight
Articles
Published in the November 2025 issue of Taxes Magazine
November 19, 2025 • 1-minute read
Stephen Josey and Phillip Clifton explain that courts are split on whether the IRS can keep the tax assessment period open indefinitely when fraud on a return is committed by someone other than the taxpayer. They note that several courts now allow preparer or advisor fraud to trigger the fraud exception under Code Section 6501(c)(1), while the Federal Circuit holds that only the taxpayer’s own intent should matter. They conclude that this divide creates significant risk for taxpayers, who must carefully supervise their advisors because others’ wrongdoing can leave old tax years permanently open.
This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.
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