EA Part 3 · Representation Before the IRS · Free Lesson

Related Issues: SOL, FOIA, Identity Theft, TAS, and Judicial Levels

Free IRS Enrolled Agent SEE Part 3 (Representation, Practices and Procedures) lesson in Representation Before the IRS. 42 min read, ~6,225 words.

A client hands you a CP2000 dated three years and one day after she filed. Whether that notice is enforceable, and where you can fight it, turns on a handful of dates and doors.

The statute of limitations is a fixed window of time. Inside it, the IRS may assess tax (formally record it as owed) or collect tax it has already assessed, and a taxpayer may claim a refund. Once the window closes, that right is gone for good, which is why you check the dates on a notice before you argue about the tax.

The statute of limitations has three separate clocks, and each one starts on a different event. Keep them apart:

Filing early does not start the assessment clock early. For assessment statute of limitations purposes, a return filed before the due date is treated as filed on the due date. So a 2025 Form 1040 filed February 10, 2026 starts its three-year clock on April 15, 2026, and that clock runs out April 15, 2029.

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Common mistakes

Bottom line

Exam shortcut

Read the date first, the issue second. Every stem in this scope hides its answer in a counted interval, so extract the notice date and the contact date before you read the facts. Stem signals to match on sight: "arithmetic error" or "invalid SSN" means math error, 60 days. "Information return does not match" means CP2000, 30 days, no court rights.

The full lesson (about 6,225 words, 42 min read) adds 2 worked examples, all 6 common mistakes, a self-check, free in the app.

Learning objectives

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