Statutes of Limitation in Florida Tax Audits
Recent case law has highlighted the “gray areas” surrounding statutes of limitation in Florida tax audits. In a sales and use tax audit, where returns are required to be filed each month, the law creates a separate three-year limitations period for each month in the audit. As things currently stand, there is a question as to whether the “automatic” tolling of the limitations period during an audit adds additional time to the limitations periods for each of these months. Put simply, if the audit report is issued after the tolling period ends, has the Department lost the ability to assess tax against the early months in the audit? This presentation dives into the issues and offers ways to think through the consequences for taxpayers.
Speaker: Steven M. Hogan, with the Ausley McMullen Law Firm in Tallahassee, Florida. www.ausley.com