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TXX5766 USAco, a domestic corporation, filed its return for year 1 on March 15 o

ID: 2593101 • Letter: T

Question

TXX5766

USAco, a domestic corporation, filed its return for year 1 on March 15 of year 2. The IRS is auditing USAco's year 1 return. USAco is recalcitrant and fails to respond to any request for information from the IRS, including the IRS's summons for information. If
the IRS is concerned about the statute of limitations expiring without obtaining any information to make an assessment, the IRS will issue USAco:

another summons.

an information document request.

a formal document request.

a designated summons.

a)

another summons.

b)

an information document request.

c)

a formal document request.

d)

a designated summons.

Explanation / Answer

Answer:- d. A designated summons

Explanation :- The running of the applicable period of limitations on assessment provided for in section 6501 is suspended with regard to any return of tax by a corporation that is the subject of a designated or related summons if the court proceedings is instituted with respect to that summons.