Discussion:NOL and Statute of Limitations
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| + | {{ForumReplyPost|UserID=SCCPA|Date=17 July 2009|Text=It is not necessarily "off limits." They just can't propose an assessment for 2001 - 2005 if the statute has run on those years. They can, however, make adjustments to the 2001 - 2005 returns years that would effect the amount of carryforward into open years (presumably 2006 and 2007), and they can propose assessments for those open years based on changing the NOL in the closed years.}} | ||
Revision as of 19:37, 17 July 2009
Discussion Forum Index --> Advanced Tax Questions --> NOL and Statute of Limitations
Discussion Forum Index --> Tax Questions --> NOL and Statute of Limitations
| 17 July 2009 | |
| I am currently working on an IRS audit for 2007. A large farm loss was incurred in 2001 and was elected to be carried forward. By 2007 it had not been entirely used. The examiner has sent a document request wanting information for all the intervening years. He states "in order for the NOL to be deductible, we need to verify the income and expenses for all these years. Please provide books and records used to prepare the Sch. F for these years."
My question, does the 3-year statute of limitations have any exceptions due to NOL's? In other words, am I right in thinking this info can be off-limits to him? This audit is one of IRS' NRP audits. It's the third one I had for '07. The previous two were a piece of cake, this examiner has made this particular audit a full-time job for himself. It didn't help that my client failed to report a $15,000 deposit in his records. This still isn't a "substantial omission" (25% or more of gross income). Thanks in advance. | |
| 17 July 2009 | |
| It is not necessarily "off limits." They just can't propose an assessment for 2001 - 2005 if the statute has run on those years. They can, however, make adjustments to the 2001 - 2005 returns years that would effect the amount of carryforward into open years (presumably 2006 and 2007), and they can propose assessments for those open years based on changing the NOL in the closed years. | |
