When IRS makes an assessment of tax allegedly due, such tax may be collected by levy or court proceeding, but only if the levy is made or the proceeding begun within 10 years after assessment of said tax liability, 26 U.S.C. § 6502.
If, however, a timely proceeding in court for the collection of said tax is commenced, the period during which such tax may be collected by levy is extended and does not expire until the liability for the tax—or judgment against the taxpayer arising from such liability—is satisfied, id.
Should an alleged taxpayer petition the U.S. Tax Court to challenge an assessment, all collection activity is suspended while the court proceeding is underway.
Should an alleged taxpayer lose in U.S. Tax Court, a new assessment is made and IRS and U.S. Department of Justice get a fresh 10-year period to levy or begin…
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