On occasion, the IRS issues what are called “field service advice.” These are legal opinions designed to assist IRS employees in dealing with taxpayers. The opinions are not legally binding on taxpayers, but knowing what they say can be helpful.
In a field service advice dated March 31, 2015, the question was raised when one type of federal tax return is required from the employer, but another type is filed, is the filed return valid? And then on what date does the period of limitations for assessment of tax begin to run? The field service advice said the document filed constitutes a valid return “if the document contains sufficient data to calculate the tax liability, purports to be a return, is an honest and reasonable attempt to satisfy the requirements of the tax law, and is executed under penalties of perjury.” The document went on to say that it’s filing date starts the running of the period of limitations on assessment.