Kane & Company, Certified Public Accountants And Advisors

Episode 6: Omission from Gross Income for Purposes of the Six-Year Minimum Period for Assessment

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Sinopse

After it lost court cases on whether a basis overstatement is an omission of gross income for purposes of the longer limitations period, the IRS recently modified treasury regulations to make clear that a basis overstatement can trigger the six-year statute of limitations period. In so doing, the IRS sought to strengthen its position, which has been rejected in the Tax Court and two circuit courts this year.