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and when the irs audited him, found the error, and demanded payment.

he made it.

the issue then is that the IRS could not go after two years, even though they could see it was wrong.

so he didn't pay them right away.

are you telling me that if the IRS audited you, and found an error in your 2005 return, that was also there for your 2001 to 2004 returns, you would voluntarily pay that back taxes, even though they have no way to demand the payment?


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