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Taxation & Estate Planning

: TaxProf Blog

Federal Circuit Exacerbates Split on Overstatement of Basis and 6-Year SOL

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The Federal Circuit yesterday exacerbated the split in the circuits in holding that a taxpayer's overstatement of basis was an omission of income under § 6501(e) and thus triggered the six-year statute of limitations. Grapevine Imports Ltd. v. United States, No. 2008-5090 (Fed. Cir. Mar. 11, 2011). Kristin Hickman (Minnesota):...

Full post as published by TaxProf Blog on March 12, 2011 (boomark / email).

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BASIS OVERSTATEMENT DOES NOT TRIGGER 6 YEAR STATUTE OF LIMITATIONS

Circuit Split on Sentencing

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APPEALS COURT BREATHES NEW LIFE INTO OVERSTATED BASIS ISSUE

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