The IRS is not shy when it comes to flexing its Federal muscles. In a 2001 Chief Counsel Advice Memorandum, rather like a bodybuilder at the beach, the IRS so flexed (observed): The federal government is not barred by any state statute of limitation periods (or otherwise labeled claim extinguishment provisions) from enforcing its rights under the Internal Revenue Code to assess or collect taxes, even though the federal government may be relying on state