위의 사항은 IRS에 분류하는 이슈 중에서 다음과 같은 사항같습니다.
IRS Examination of Return and Assessment of Additional Tax
위의 이슈는 Omissiom of More than 25% of Gross Income without Adequate Disclosure과 다른 이슈입니다.
즉 IRS Examination of Return and Assessment of Additional Tax는
Statutue of Limitation (SOL)이 3년입니다.
아래는 IRC에서 발췌한 글입니다.
(c) Exceptions에 열거되어 있는 사항에 해당되지 않으면, 3년이 SOL입니다
(a) General rule
Except as otherwise provided in this section, the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed (whether or not such return was filed on or after the date prescribed) or, if the tax is payable by stamp, at any time after such tax became due and before the expiration of 3 years after the date on which any part of such tax was paid, and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period. For purposes of this chapter, the term “return” means the return required to be filed by the taxpayer (and does not include a return of any person from whom the taxpayer has received an item of income, gain, loss, deduction, or credit).
http://www.law.cornell.edu/uscode/text/26/6501
