“I am a CPA with almost 40 years experience. Actually was a tax law professor at a large university years ago.. retired now but still do IRS Audits and Tax Court Cases.”
Then you should know that you gave bad advice on the IRS statute of limitations.
The ten year period of for starting the legal actions to recover owed taxes.
Additionally, if there is fraud, a willful attempt to evade taxes or missing return there is no time limit.
I’ve won many cases over the years on this exact issue....
Just had two of them this tax season. Easier to work around than fight. We just filed an extension on one as they were near the 10 year limit and will file the return as soon as it expires. No need to let them keep the refund.
I just recently settled a $115,000 balance due for a client from 2012 individual return by fighting it in Federal Bankruptcy Court. Settled it for $1,500 without going to court. Much easier to win there than Tax Court.