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KPMG article: A refresher on tax statutes of limitations

Taxpayers should be aware of the various differences in statutes of limitations and their rights and options.

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may 26, 2026

Statutes of limitations in the tax world are a two-way street. In the assessment context, they favor taxpayers by limiting the time the IRS can examine and adjust items on a federal tax return. Other times they favor the IRS by limiting the time taxpayers can make claims for refunds or credits.

The validity of a particular adjustment by the IRS or a refund claim by a taxpayer should not factor into the determination of whether a particular statute of limitations applies. This is because statutes of limitations “are by definition arbitrary, and their operation does not discriminate between the just and the unjust claim, or the voidable and unavoidable delay.”

Read a May 2026 article* in which the KPMG authors examine various statutes of limitations for assessment and refund claims as well as options for extending the limitations periods in both contexts.

* This article originally appeared in Tax Notes Federal (May 11, 2026) and is provided with permission.

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