[Code of Federal Regulations]
[Title 26, Volume 18]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR301.6521-2]

[Page 389]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 301_PROCEDURE AND ADMINISTRATION--Table of Contents
 
                               Limitations
 
Sec. 301.6521-2  Law applicable in determination of error.

    The question of whether there was an erroneous treatment of self-
employment income or of wages is determined under the provisions of law 
and regulations applicable with respect to the year or other taxable 
period as to which the error was made. The fact that the error was in 
pursuance of an interpretation, either judicial or administrative, 
accorded such provisions of law and regulations at the time the action 
involved was taken is not necessarily determinative of this question. 
For example, if a later judicial decision authoritatively alters such 
interpretation so that such action is contrary to the applicable 
provisions of the law and regulations as later interpreted, the error 
comes within the scope of section 6521.

              Periods of Limitation in Judicial Proceedings