>> failing to file a tax return in 2001
If the IRS cannot prosecute the “failure to file” within a timely manner, then the govt should have no standing in further actions.
There should be a statute of limitations along with better efficiency in tracking delinquencies — otherwise, it’s a swamp of Columbo-style investigations chasing down revenue that’s likely off the Fed’s books.
There is no statute of limitations on failure to file as the act of filing triggers the statutory period of examination and assessment.