A few jurisdictions permit tax authorities to toll
statutes of limitation for assessments by unilateral administrative action (e.
Division 2's approach has the advantage of providing greater certainty and predictability to government agencies as to their own liability, which is the general purpose of all
statutes of limitations.
Statutes of limitations are useful in that they are more or less a procedural barrier that appeals to the other party.
Tolling rules for criminal
statutes of limitations vary from state to state, but several common tolling provisions deserve mention.
Statutes of limitations originated under Roman law and continue to exist in modern European and American law today.
The absence of such clauses, much to the surprise of the parties to such contracts, may lead to an arbitral ruling that
statutes of limitations do not apply to the parties' dispute.
For instance, the state of Rhode Island was limited by
statutes of limitation to recovery for public buildings, (96) and the city of Philadelphia was denied reliance on nullum tempus because it is a municipality, while the Philadelphia Housing Authority was protected because it is an agency of the Commonwealth.
By so doing, this Note will offer a comprehensive view of the RICO statute of limitations that is consistent not only with the current state of the law but also with the purposes of
statutes of limitations generally.
First, taxpayers should be authorized to request Competent Authority assistance before pursuing a case with Appeals in order to mitigate problems associated with "hazards of litigation" settlements in Appeals and with foreign
statutes of limitations.
Suspension of State
Statutes of Limitation by Unilateral State Action
Becoming familiar with the federal and state
statutes of limitations for tax enforcement is important for CPAs because it can help them understand a taxpayer's rights and responsibilities.
While the two cases discussed here resulted in "wins" for the defendant appraisers,
statutes of limitations should not be considered a reliable safety net, and such wins are rare in practice.
