26 U.S.C. 6501(c)(1), (c)(3) and (e)(1)(A): no limit for a false return or no return, 6 years for a large omission (26 U.S.C. 6501(c)(1), (c)(3), (e)(1)(A))
The window has no end for a fraudulent return or a return never filed, and runs 6 years when income left off a return exceeds a quarter of the income stated.
Dated 31 Oct 2026Source checked 31 Oct 2026Basis: primary text
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In the source's own words
“In the case of a false or fraudulent return with the intent to evade tax, the tax may be assessed, or a proceeding in court for collection of such tax may be begun without assessment, at any time. ... In the case of failure to file a return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time. ... such amount is in excess of 25 percent of the amount of gross income stated in the return ... at any time within 6 years after the return was filed.”
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