Technical topics regarding tax preparation.
SOL Application
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25-May-2018 7:41am

Good morning. I am confused on the the three year SOL. I have worked cases going back to 2007 who have been adjusted, OIC for old balances, and form 843 for old trust fund where no 1153 issued. However, how does the SOL states that no credit or refund is applicable after 3 years? Arent these actions taken a credit to the account?

25-May-2018 9:04am

Aren't these actions taken a credit to the account?

No. More like abatements. If the SOL expires, you can’t obtain a cash refund for any overpayment, nor can you say, “Please credit that overpayment to next year’s liability,” for example. So, it’s referring to payment by credit.

25-May-2018 9:33am

Thank you for responding. Makes perfect sense.
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