Technical Advice Concludes That A $1 Nominal Claim Will Not Protect The Statute of Limitations

According to ProcedurallyTaxing, Chief Counsel’s office issued Program Manger Technical Assistance (PMTA) 2023-001 to address the issue of a $1 claim filed in order to try to protect the statute of limitations for filing claims.  The advice concludes that the $1 or any nominal claim will not protect the taxpayer but it also distinguishes nominal claims from protective claims. 

It then goes on to state that "A late-filed claim will not be treated as an amendment or “supplement” to an original claim if it would require the investigation of new matters that would not have been disclosed by the investigation of the original claim."

Essentially, the PMTA takes the position that putting down a nominal amount does not create the type of informal claim a taxpayer can later fix.  

For more regarding exceptions to this rule go to ProcedurallyTaxing.

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