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Statute of Limitations for Issuing a Deficiency Assessment (R&TC Section 19755)

Notices Issued Prior to August 1, 2011

The FTB has 8 years after a taxpayer files a return to mail a proposed deficiency assessment relating to an abusive tax avoidance transaction as defined under R&TC Section 19753(c). This extended period is applicable for returns filed on or after January 1, 2000.

Notices Issued Beginning August 1, 2011

The FTB has 12 years after a taxpayer files a return to mail a proposed deficiency assessment relating to an abusive tax avoidance transaction as defined under R&TC section 19777. This extended period is applicable for notices mailed beginning August 1, 2011, for tax years not closed as of August 1, 2011.