Liquidating trustee statute of limitations

Section 6511 provides the limitations period within which a taxpayer must file a claim for credit or refund and restricts the ability of the Secretary to issue a credit or refund unless the claim is filed by the taxpayer within that period.

Section 7422 prohibits the maintenance of a suit for refund until a claim has been duly filed with the Secretary.

These final regulations remove outdated portions of § 301.6402–2 that provided rules for claims filed prior to April 15, 1968 and § 301.6402–3 that provided special rules for claims for credit or refund of income taxes filed before July 1, 1976, and revises the reference in § 301.6402–4 to reflect the threshold for referral to the Joint Committee on Taxation pursuant to section 6405.

These final regulations do not affect § 301.6402–3T as promulgated in Treasury Decision 9658 (79 FR 12880) (March 6, 2014).

Additionally, this document provides notice of proposed modifications to Rev. 93––43 relating to the issuance of interests in partnership profits to service providers.

This announcement describes future changes to the determination letter program for qualified individually designed plans and sets forth an intended transition period for certain plans.

Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.

In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.

Section 6402 of the Code authorizes the Secretary to make credits or refunds of overpayments.

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin.

All published rulings apply retroactively unless otherwise indicated.

Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

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