Advertisement In Fairbank v. Commissioner, T.C. Memo 2023-19 (Feb. 23, 2023), the Tax Court ruled that the three-year statute of limitations did not bar assessment. On April 12, 2018, the IRS issued to Leigh and Barbara Fairbank a notice of deficiency for tax years 2003-2009. Because the Fairbanks timely filed their tax returns, they asserted that … Continue reading Foreign Account Keeps Three-Year Statute of Limitations Open