I have never seen the IRS assert CODI. Let me take a quick look. I assume no other exception exists – there are many under 108. As the collection statute is 10 years- a strong position is that the IRS walked away from this year's ago and the statute for COD is closed. Perhaps that is the way they look at it.
Very truly yours,
ROBERT S. BARNETT
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Original Message:
Sent: 2/17/2023 10:24:00 AM
From: Patricia Giunta
Subject: Collection Statute Expiration Date
A client has had the Collection statute expire on an outstanding assessment. Is it possible that this is not cancellation of debt income?
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Patricia Giunta
JTS Associates CPA's P.C.
Westbury NY
patricia.giunta@jtshulman.com
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