On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC § 6501(a), or whether the statute of limitations remained open due to fraud under IRC § 6501(c)(1). Summary1 “Sarah, I feel like I don’t even know you.” “It’s Vivian. Would