u201cCan the IRS still collect monies owedu201d MaybeAs you mention a criminal prosecution is probably barred.Whenever we talk about fraudulent returns we must distinguish between criminaltax fraud offenses under IRC Sec 7201 and civil tax fraud offenses under IRCSec 6663. These offenses have different i burdens of proof ii penaltiesiii statutes of limitations and iv prdifferent defenses to thetaxpayer.In criminal tax fraud the Statute of Limitations applies to the prosecutionof the crime but not to the assessment of taxes. It is complicated buttypically the SoL in criminal fraud is 3 years from the commission of thecrime or 6 years for specified carved out offenses.In civil tax fraud there is no Statute of Limitations. But the IRS must meet au201cclear and convincingu201d evidentiary standard preponderance of evidence.I did not see it mentioned in the New York Times article but keep in mindthat an IRS attorney or attorneys and auditors at New York DistrictCounselu2019s office would have reviewed Fred Trumpu2019s Estate Tax Return Form 706including attached appraisals and 709s and then issued a u201cClosing Letteru201d.This may or may not preclude the IRS from pursuing the Trump Estate but doespra hurdle to overcome in proving fraud and collecting taxes. We wouldhave to see the workpapers and notes that went into issuing that u201cClosingLetteru201d.