26 C.F.R. § 301.6514(b)-1 Credit against barred liability.
Title 26 - Internal Revenue
Any credit against a liability in respect of any taxable year shall be void if the collection of such liability would be barred by the applicable statute of limitations at the time such credit is made. Mitigation of Effect of Period of Limitations
Title 26: Internal Revenue
PART 301—PROCEDURE AND ADMINISTRATION
Limitations
Limitations on Assessment and Collection
§ 301.6514(b)-1 Credit against barred liability.