Irc 6532 a 1
Web§ 301.6532-1 Periods of limitation on suits by taxpayers. ( a) No suit or proceeding under section 7422 (a) for the recovery of any internal revenue tax, penalty, or other sum shall be … Webthere is an installment agreement between the taxpayer and the Secretary, prior to the date which is 90 days after the expiration of any period for collection agreed upon in writing by the Secretary and the taxpayer at the time the installment agreement was entered into; or I.R.C. § 6502 (a) (2) (B) —
Irc 6532 a 1
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WebIRC § 6532 are not jurisdictional and, moreover, that plaintiff’s petition was timely filed), and Howard Bank v. United States, 759 F. Supp. 1073, 1080 (D. Vt. 1991), aff’d, 948 F.2d 1275 (2d Cir. 1991) (applying equitable principles to IRC § 6532 and estopping the IRS from raising the limitations period as a bar to suit). 10 IRC § 6532(c). WebNov 22, 2024 · In such cases, the courts have held that the IRS is equitably estopped from arguing that the taxpayer is barred from bringing suit under IRC § 6532. If the IRS issues a notice of disallowance, and the taxpayer allows the two-year period for filing suit to expire, the taxpayer may not, thereafter, revive the right to file suit by filing a ...
Webant to IRC § 6532(a), known as “statutory notices of claim disallowance,” can be stand-alone notices15 or be combined with another notice.16 In situations where a taxpayer’s claim …
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