There is no statute of limitations on failure to file as the act of filing triggers the statutory period of examination and assessment.
I’m sorry, but 17 years later they want to complain?
Maybe this has been in the works for a few years, but this is idiotic.
A filing may normally trigger examination and assessment, but there’s no guarantee the IRS will handle every situation perfectly. And for those cases that are mishandled, there should be limits.