The assessment period is extended to 6 years when a taxpayer omits from gross income an amount that is more than:
Section 6501(e)(1)(A) gives the IRS 6 years to assess when the taxpayer omits gross income in excess of 25% of the gross income stated on the return (or more than $5,000 of income from specified foreign financial assets). Overstated basis can count as an omission. Fraud or no return leaves the period open indefinitely. Source: IRC 6501(e)(1)(A); Pub. 556. Tax year: 2025 (law as of 31 Dec 2025).
Confusing the 25% omission test with the 10% substantial understatement test.
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