Webinar: The Clock Nobody's Watching §6501, Nonfilers, and the Disclosure Decision by ALFi

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Presenter

Matt Eddleman

Matt Eddleman brings more than two decades of professional experience in tax controversy, accounting, financial planning, and small business management to Frost Law's Tax Compliance team.

About

Program Field of Study: Taxes, Federal Tax Related Matters
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, tax preparers, attorneys
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None required. Familiarity with Episodes 2 and 4 (the Streamlined Filing Compliance Procedures and the Voluntary Disclosure Practice) will help attendees get the most out of Part Two, but the program recaps both before building on them.
IRS Program Number: JWRXB-T-00038-26-O

Ask most nonfilers how far back the IRS can go, and you'll get some version of the same wrong answer: three years, six years, ten years — pick a number, and assume the rest is safe. It isn't. For any tax year in which a valid return was never filed, the assessment statute of limitations under IRC §6501 never starts running at all.

This program is the fifth installment in the Coming Out of the Dark series, and it marks a shift in focus: where earlier episodes centered on international reporting failures, this session turns to the far more common file — the domestic nonfiler. We'll cover the general three-year assessment period and the handful of ways it can fail to start in the first place, including the Beard test for what actually counts as a “return.” We'll then draw the critical distinction between that legal rule and the IRS's own internal enforcement guideline, Policy Statement 5-133, which generally limits delinquency enforcement to six years as a matter of administrative practice — not law. From there, we'll connect this analysis directly to the disclosure-path decision covered in Episodes 2 and 4: quiet filing, the Streamlined Filing Compliance Procedures, or the Voluntary Disclosure Practice. A hypothetical case study ties the whole framework together, and a closing segment flags the international exceptions — covered in depth in Episode 3 — that can still surface in an otherwise domestic file.

Attendees will leave with a practical framework for evaluating a nonfiler's actual exposure, distinguishing law from IRS practice, and matching that exposure to the right compliance path.

Agenda

Identify the general three-year assessment period under §6501(a), and the circumstances under which it never starts running at all — especially for a nonfiler.
Distinguish the legal assessment period from the IRS's administrative six-year enforcement policy for delinquent returns (Policy Statement 5-133), and apply that distinction to a real filing decision.
Evaluate how the assessment statute of limitations factors into the choice among quiet filing, the Streamlined Filing Compliance Procedures, and the Voluntary Disclosure Practice.
Recognize the domestic exceptions most likely to affect an ordinary nonfiler — fraud, extensions by agreement, and substantial omission — and identify when the international exceptions from Episode 3 still apply.