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The only way I see that the three year filing deadline (the period of limitation) can be extended is if the taxpayer fails to file due to a disability. See Sec 6511(h).

There are some esoteric cases in which the limit is more than 3 years, but 6511(h) is the only authorization for honoring a late claim. It's the Oprahesque provision I was referring to. It was added by Congress, probably in an election year, in response to some sob story. Assuming that the story that motivated the action was worthy of honoring a late claim, a private bill would have been the right way to handle it. But you can't really make any good campaign use of private bills.

Luckily I had retired before this one made its way into the Code. I wasn't as fortunate back in the '70's when some boob in Pennsylvania bought real estate without title insurance, everybody except the IRS missed the properly filed notice of lien encumbering the property, and the stupid but innocent purchaser got hosed.

Congress to the rescue. They amended the Code to require IRS to maintain an "index" of all notices filed in the proper recording offices. IRS spent millions of bucks building and maintaining this totally useless database, which never benefited a single person that I heard of, until Congress quietly repealed it.

Phil
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