[Auntie Dem]

It’s the other way around. There is a six-year statute of limitations to civilly assess taxes under the 25% omission rule, but no statute of limitations for criminal evasion, which certainly appears to be present here.

That’s the way it was when I worked for the IRS in the 70’s and 80’s. I’m pretty sure the law hasn’t changed since then.

[tired&retired]

There is no Statute of Limitations on Civil Tax Fraud, only criminal tax fraud.

Here is a link to a great article explaining this in detail. I’m a retired CPA and this is the best simple explanation I have read on the subject.

“What is the Tax Fraud Statute of Limitations”

https://www.goldinglawyers.com/tax-fraud-statute-of-limitations/#:~:text=Unlike%20other%20IRS%20Statutes%20of,limitations%20for%20Civil%20Tax%20Fraud.