There are four years within which taxpayers may be assessed by the Revenue Commissioners. The time limit is an important safeguard for taxpayers, who can expect finality and closure in respect of their tax affairs once the time to assess has elapsed. There are certain circumstances in which the time limit is displaced, in which case the power to assess is open-ended. The question of whether the time limit can be displaced such that old cases can be opened in particular circumstances arises frequently before the Tax Appeals Commission (TAC) and has also come before the Superior Courts in recent years.
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