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Michael Kramarz
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Aug 14, 2026
Michael Kramarz on Twelve Years Inside the IRS as a Special Trial Attorney,
19:13
19:21
19:46
19:58

Michael KramarzGUEST
So the, the IRS has typically three years to assess tax due, and this is referred to as the statute of limitations.

Michael KramarzGUEST
Um, to the extent that the IRS is running up against that three-year window, so during an examination, you know, maybe they didn't start the exam until the end of the three-year window or maybe it's just taking a little bit longer, in order to protect its interests, the IRS will request the taxpayer sign a statute extension, giving the IRS more time to make the assessment and thus more time to undertake the examination.

Michael KramarzGUEST
Um, 98% of the time you're gonna extend a statute kind of in due course, uh, because there's some consequences if you don't, uh, that we could get into.

Michael KramarzGUEST
Um, there will be instances, though, where it doesn't make sense to extend the statute.
8 MINS LATER
