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Monthly Archives: April 2012

Supreme Court Tells IRS 3 Years To Audit Is PLENTY! (Continued)

Home Concrete & Supply, LLC, (Sup Ct4/25/2012) 109 AFTR 2d 2012-661 The Supreme Court, resolving a split among various Circuit Courts and the Tax Court, has determined that an overstatement of basis isn't an omission of gross income for purposes of Code Sec. 6501(e)(1)(A)'s 6-year limitations period. The Court found that the '58 Colony decision,…
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IRS Contemplates Guidance Clarifying Rescission Doctrine, Alexander Says

The Internal Revenue Service continues to contemplate the contents of a possible guidance project to assist taxpayers when applying the rescission doctrine after the Service ruled in January that it will no longer offer additional interpretations of the doctrine, IRS Associate Chief Counsel (Corporate) William D. Alexander said. Currently taxpayers have only a 32- year-old…
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Supreme Court Tells IRS 3 Years To Audit Is PLENTY!

Forbes - Even the IRS has limits. If you’ve ever been audited by the IRS, you may think going back three years is bad enough. The tax code generally allows the IRS to audit three years back, and six in some cases. The U.S. Supreme Court in U.S. v. Home Concrete & Supply, LLChas dramatically…
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