26 U.S.C. § 6204
Supplemental assessments
The Secretary may, at any time within the period prescribed for assessment, make a supplemental assessment whenever it is ascertained that any assessment is imperfect or incomplete in any material respect.
For restrictions on assessment of deficiencies in income, estate, gift, and certain excise taxes, see section 6213.
1976—Subsec. (a). Pub. L. 94–455 struck out “or his delegate” after “Secretary”.
1974—Subsec. (b). Pub. L. 93–406 substituted “gift, and certain excise taxes” for “and gift taxes”.
Amendment by Pub. L. 93–406 applicable, except as otherwise provided in section 1017(c) through (i) of Pub. L. 93–406, for plan years beginning after
Notes of Decisions
Cited in 23
cases (3 in the last 5 years), 1959–2024 · leading case: Carroll Eugene Singleton, and Sheila Singleton v. United States
Carroll Eugene Singleton, and Sheila Singleton v. United States (1997)
“When the IRS realized its mistake, in 1991, the government argued, it properly made a “supplemental assessment,” pursuant to 26 U.S.C. § 6204 , for the full amount of tax reported on the Singletons’ original return.”
Thomas A. Johnson v. United States of America, Acting by and Through Department of Treasury Irs (1997)
“This appeal raises the issue of whether the Internal Revenue Service (“IRS”) may make a supplemental assessment pursuant to 26 U.S.C. § 6204 while litigating the validity of the original underlying assessment.”
Raymond E. And Dorothy J. O'Bryant v. United States (1995)
“26 U.S.C. § 6204 . Occasionally, the IRS sends a taxpayer a refund check.”
United States v. Walter H. Schroeder, Josephine J. Schroeder, and Louis Brodnan (1990)
“The defendants had argued that the United States’s pre-trial concession voided the 1980 assessment and created a supplemental assessment pursuant to 26 U.S.C. § 6204 that was barred by the statute of limitations.”
United States of America, Creditor-Appellant v. John F. Frontone and Kathleen M. Frontone, Debtors-Appellees (2004)
“A different conclusion would, by extending the availability of supplemental-assessment procedures to cases involving posting errors, create tension with 26 U.S.C. § 6204 . That section, as we know, authorizes “a supplemental assessment whenever it is ascertained that any…”
Clark v. United States (1995)
“26 U.S.C. § 6204 . *85 Once it makes an assessment of a taxpayer's tax liability for a given year, the IRS generally has sixty days to issue a notice and demand for payment to the taxpayer, 26 U.”
United States of America v. Arthur Andersen & Co., and Good Hope Industries, Inc., Intervenor (1980)
“26 U.S.C. § 6204 . 3 . 26 U.S.C. § 7602 provides: “For the purpose of ascertaining the correctness of any return, making a return where none has been made, determining the liability of any person for any internal revenue tax or the liability at law or in equity of any transferee…”
Francis H. Ameel, Administrator D.B.N. Estate of Mary E. Ameel v. United States (1970)
“The ability of the Government to assert additional assessments however, is granted to it by statute, Section 6204(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 6204 (a) (1964), and may be cut off only by applicable statutory limitations on further assessment.”
First of America Bank-West Michigan v. Alt (1993)
“See 26 U.S.C. § 6204 (a); Brookhurst, Inc. v.”
Kurio v. United States (1970)
“26 U.S.C. § 6204 . A commentator has noted: The principle of self-assessment by the taxpayer would collapse if the Commissioner were completely at liberty to reject the taxpayer’s statement of income simply because such statement of income does not approximate the average income…”
United States v. Vorachek (1977)
“The supplemental assessments were made pursuant to 26 U.S.C. § 6204 (a). On August 23,1976, a tax assessment of $7,163.”
Allan v. United States (1975)
“26 U.S.C. § 6204 (a): (a) General rule. — The Secretary or his delegate may, at any time within the period prescribed for assessment, make a supplemental assessment whenever it is ascertained that any assessment is imperfect or incomplete in any material respect.”
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