Tenth Circuit Rules that Statute of Limitations for Basis Overstatements is 6, not 3, Years

The saga over what is the correct statute of limitations for basis overstatements continues. Paul Caron reports: The Tenth Circuit yesterday reversed the Tax Court and held that Reg. § 301.6501(e)-1 is entitled to Chevron deference…

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Basis Overstatements and the Statute of Limitations on Assessment

Paul Caron reports that the Fifth Circuit has now joined the Fourth and the Ninth in holding that the an overstatement of basis is not the same as an omission of income and, therefore, the extended…

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The 10 Year Statute of Limitations on Collection of an IRS Debt

The IRS has ten (10) years from the date of a tax assessment to collect a debt from the taxpayer. The date the collection statute expires is called the Collection Statute Expiration Date or CSED. When this…

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Tax Court Update – January 2009 – Statute of Limitations on Assessment

David Loeb v. Commissoner of Internal Revenueand Harold Molaison v. Commissioner of Internal Revenue (Consolidated) – The issue for decision in these consolidated cases was whether the statute of limitations barred the IRS’ issuance of the…

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