The rules the exam tests
| Rule | What it says (2025) | Source |
|---|---|---|
| Assessment | 3 years; early returns deemed filed on due date | IRC 6501(a), (b)(1) |
| Substantial omission | 6 years: > 25% of gross income, or > $5,000 of foreign-asset income | IRC 6501(e) |
| Unlimited | Fraud, willful evasion, no return | IRC 6501(c) |
| Unfiled foreign info returns | Open until information furnished | IRC 6501(c)(8) |
| Extension | Form 872 (fixed) / 872-A (open); right to refuse or limit | IRC 6501(c)(4) |
| Collection (CSED) | 10 years from assessment; suspended by OIC, IA request, CDP, bankruptcy, 6+ months abroad | IRC 6502, 6331(k) |
| Refund claim | Later of 3 years from filing or 2 years from payment; lookback limits | IRC 6511(a), (b) |
| Bad debt / worthless security | 7 years | IRC 6511(d)(1) |
| Prompt assessment (decedents) | Form 4810: 18 months | IRC 6501(d) |
| Tax Court case | Assessment suspended while barred, + 60 days | IRC 6503(a) |
Facts: A taxpayer filed her 2021 return on time (April 18, 2022) showing $100,000 of gross income. She left off $30,000.
Result: $30,000 is 30% of reported gross income (> 25%), so the IRS has 6 years, until April 18, 2028, instead of April 18, 2025. Had she filed a fraudulent return, there would be no limit.
Exam traps
- An early return starts the clock on the due date.
- The 25% test compares the omission with gross income stated on the return.
- Refund lookback limits how much you get back, not just whether you can file.
- CSED suspensions add time; consents on Form 872 extend assessment only.
Statutes of limitations (assessment, refund, collection): 10 free practice questions
Statutes of limitations (assessment, refund, collection) practice questions
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Frequently asked questions
How far back can the IRS audit?
Usually 3 years after filing, 6 years for large income omissions, and without limit for fraud or unfiled returns.
How long does the IRS have to collect?
10 years from the date of assessment, extended by suspension events such as a pending offer in compromise or bankruptcy.
Sources
- 26 U.S.C. 6501 - Limitations on assessment and collection (accessed 2026-09-23)
- 26 U.S.C. 6502 - Collection after assessment (accessed 2026-09-23)
- 26 U.S.C. 6511 - Limitations on credit or refund (accessed 2026-09-23)
- IRS Publication 556 - Examination of Returns, Appeal Rights, and Claims for Refund (accessed 2026-09-23)
- IRS - SEE Part 3 content specifications (Representation, Practices and Procedures) (accessed 2026-09-23)
- IRS - Enrolled agents: Frequently asked questions (accessed 2026-09-23)