Skip to content

If...

Example:

Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States

Assume the IRS issues a SNOD on June 1, 2020, for a Form 5330 return with a statute expiration date of July 31, 2020. The taxpayer has 90 days (until August 30, 2020) to petition Tax Court. The statute of limitations would be "extended" to December 28, 2020, (150 days are added to the original statute date) by the issuance of the 90-Day Letter. However, if the taxpayer signs Form 870-EP on June 21, 2020 (with 70 days remaining in the 90-day period), the statute of limitations would be shortened by 70 days to October 19, 2020.

Update the statute of limitations on AIMS and RCCMS after you mail the 90-Day Letter and when the taxpayer signs Form 870-EP or Form 4089.

Get a plain-English answer with a citation back to this text.

Ask AI about this code
▸Contents — Internal Revenue Manual Part 4. Examining Process

GoCodebook provides public access, search, citation, multilingual explanation, and practical interpretation of legally adopted building regulations. It is not a substitute for the official ICC or California code publications.