ATTORNEY GERARD LEVINS: Levins Tax Law is a boutique law firm specializing in representation of taxpayers, both individuals and businesses, people both at the federal level and at the state tax level.
In general the statue of limitations for assessment in a civil tax case is three years from the due date or the date the tax return was filed, whichever is later. If the tax return is false or fraudulent, the statue of limitations for criminal prosecution is six years from the date of infraction. The FBAR is due June 30th of the subsequent year. If it is a civil tax fraud case, there is no statue of limitations for assessment. In general, the statute of limitations for the IRS to collect taxes is 10 years from the date of assessment.