Instead, courts have developed the discovery rule, providing that the statute of limitations in fraud cases should typically begin to run only when the injury is or reasonably could have been discovered.

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Under the applicable statute of limitations for securities fraud, the government generally must bring charges within five years of the trade in question.

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Fortunately, the statute of limitations likely bars the IRS from going back any further than 2008 (assuming no fraud and timely filings).

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