Fiscal Year 2026 Review of Assessment Statute Extension Dates

Report Information

Summary

The IRS complied with the legal requirement to notify taxpayers and their authorized representatives of their rights when requesting an extension of the statute of limitations for assessing additional taxes. We selected a statistically valid stratified random sample of 72 out of 6,539 taxpayer case files closed from April 1, 2024, through March 31, 2025, where the IRS extended the assessment statute expiration date. We reviewed consent forms in 68 of 72 taxpayer case files. For the four remaining files, the assessment statute was automatically extended and consent forms were not required. We did not identify any instances where the IRS failed to:

• Provide notice to the taxpayers of their rights to decline to extend the assessment statute of limitations.
• Request that any extension be limited to a specific period of time or specific issues. In all 68 taxpayer case files reviewed, the legal requirements were satisfied when the taxpayers or the taxpayers’ representatives signed Form 872, Consent to Extend the Time to Assess Tax, Form 872-M, Consent to Extend the Time to Make Partnership Adjustments, or Form SS-10, Consent to Extend the Time to Assess Employment Taxes. The taxpayers’ rights are clearly specified on the forms.

Management Response

The IRS agreed with the draft report but did not provide a formal response.