Webinar: Time's Up: Statutes of Limitations in Federal Tax Practice by ALFi

Presenters

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

About

Program Field of Study: Taxes
Program Level: Basic
Who Should Attend: CPAs, Enrolled Agents, Attorneys, Small Business Owners
Credits: 1 CPE, 1 CE
Advanced Preparation: none
Prerequisite: none
IRS Program Number: JWRXB-T-00030-26-O

Nearly every tax controversy turns on a date. This session surveys the limitations periods that govern federal tax practice—how long the IRS has to assess, how long it has to collect, how long a taxpayer has to claim a refund, and how long the government has to recover a refund it never should have paid—along with the many provisions that extend, suspend, or eliminate those periods entirely. Attendees will work through the relationships among these periods, the circumstances that leave a period open indefinitely, and the judicial filing deadlines that follow an IRS determination. The session also addresses recent developments regarding whether missed court deadlines can be excused, and touches on state limitations periods that diverge from the federal rules.

Agenda

Identify the general assessment period and the circumstances that extend or eliminate it
Explain how the collection period is calculated and the events that suspend it
Determine whether a refund claim is timely, and how long the government has to recover a refund paid in error
Recognize the judicial filing deadlines that follow IRS determinations and the consequences of missing them
Compare selected state limitations periods with their federal counterparts