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Preparer’s fraud means no deadline for IRS assessment

Murrin v. Commissioner, No. 24-2037, 2025 BL 373163 (3d Cir. Oct. 17, 2025), Court Opinion

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Tax Coda
Oct 24, 2025
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The Third Circuit held that the section 6501(c)(1) “false or fraudulent return with the intent to evade tax” exception does not require the taxpayer’s own fraudulent intent, so the IRS may assess at any time when a return is fraudulent due to a third party, such as a preparer.

Holding

The court affirmed the Tax Court. Section 6501(c)(1) applies when a fal…

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