Reply To: Statute of Limitations

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#10241
Eric Green
Keymaster

Bryan, by amending the 941s and 940 it should take care of the penalties. They would then amend the partnership and 1040s for any open year (within 3 years). If they can’t then they can’t. As long as the partners did pick up the income (whether incorrectly through W-2 or not) the IRS should not get too bent out of shape about it, but I see no reason why the three year window should be expanded to 6. Nothing you mentioned has any suggestion of fraud.

Eric