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Taxation & Estate Planning

: TaxProf Blog

7th Circuit: Overstatement of Basis Is Omission of Income, Triggering 6-Year SOL

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The Seventh Circuit handed the IRS a big victory today in a Son-of-BOSS tax shelter case, treating a taxpayer's overstatement of basis as an omission of income under § 6501(e), triggering the six-year (not three-year) statute of limitations. Beard v. Commissioner, No. 09-3741 (7th Cir. Jan. 26, 2011). For a...

Full post as published by TaxProf Blog on January 26, 2011 (boomark / email).

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