Interest and Penalties Paid in Prior Two Years May Be Abated by IRS Even Though Amended Return Reducing Tax Filed After Statute Expired on Claiming Refund of Taxes

In emailed advice (Chief Counsel Email 201520010) the IRS concluded that the agency had the authority to abate interest and penalties in a situation where the penalties and interest had been paid and an amended return was filed after the date on which the statute of limitations for claiming a refund of taxes on the year in question had expired.

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