General Rule: In any case in which a tax has been assessed within the applicable statutory period of limitations on assessment, a proceeding in court appeal may be made within 10 years of assessment.  Agreement to extend the period of limitations on collection : The Secretary may enter into an agreement with the taxpayer to extend the period of limitations on collection in the following circumstances:

1 Extension to extend the period of limitations on collections with an installment agreement. If the Secretary and the taxpayer enter into an installment agreement for the tax liability prior to the expiration of the period of limitations on collection The Secretary and the taxpayer, at  the time the installment agreement is entered into, may enter into a written agreement to extend the period of limitations on collection to a date certain. A written extension agreement entered into shall extend the period of limitations on collection until the 89th day after the date agreed upon in the agreement 

2. Extension agreement entered into in connections with the release of a levy under section 6343 If the Secretary has levied on any part of the taxpayer's property prior to the expiration of the period of limitations on collections and the levy is subsequently release pursuant to section 63453 after the expiration of the period of limitations on collection, the secretary and the taxpayer, prior to the release of the levy may enter into a written agreement to extend the period of limitations on collection to a date certain. A written extension agreement entered into under this paragraph shall extend the period of limitations on collection until the date agreed upon in the extension agreement.

3 Proceeding in court for the collection of the tax. If a proceeding in court for the collection of a tax is begun within the period provided (10 years) during which the tax may be collected by levy is extended until the liability for the tax or a judgment against the taxpayer arising from the liability is satisfied or is unenforceable.

4 Effect of statutory suspensions. Any statutory suspension of the period of limitations on collection tolls the running of the period of limitations on collection as extended pursuant to an executed extension agreement for the amount of time set forth in the relevant statute.



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