Statute of Limitations - Tax Court Docketed Cases

IRS released Chief Counsel Advice 201644020. The most interesting takeaway is that it is the IRS' belief that that statute of limitations on assessment will be suspended when a case is placed on the Tax Court docket for a deficiency hearing, even is there is no deficiency notice that has been issued.


Interesting piece of tax procedure in that the statutory notice of deficiency is not key for suspending the assessment statute.


Relevant Citations: Chief Counsel Advice 201644020