Question

what is the statute of limitations on charging anclient with tax evasion under Section 7201?

Answer 1

As per Section 7201 and supreme court judgement ( sansone VS united states ):
 Bare Act language:  In case of Attempt to evade or defeat tax any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof shall, in addition to other penalties provided by law, be guilty & upon conviction thereof, shall be filed not more than $250,000 and $500,000 in the case of a corporation or imprisoned not more than 5 years, or both, together with the costs of prosecution.

As per supreme court 2 cases are covered in this section -

1) taxpayer attempt to evade tax assessment

2) attempt to evade tax payments

Now the period od limitation is generally 3 years from the date of commisiion of fraud.

And six years in the given 8 circumstances which included Fraud etc.

Period of limitation means the time period with which fraud shall be detected by the Tax authorities and notice can be served on Assessee for the assessment and payment of evaded amount.