Limitation exclusion for refund claims allows rectified filings after deficiency memos to be treated as continuations when supported by documents.
The period between filing an original refund application and the communication of a deficiency memo is excluded from the computation of the limitation period, so that rectified refund applications filed with supporting documentation after receipt of the deficiency communication are treated as a continuation of the original claim rather than as fresh proceedings. (AI Summary)
The period between filing an original refund application and the communication of a deficiency memo is excluded from the computation of the limitation period, so that rectified refund applications filed with supporting documentation after receipt of the deficiency communication are treated as a continuation of the original claim rather than as fresh proceedings. (AI Summary)
TaxTMI