Beard v. Comm'r, 2011 U.S. App. LEXIS 1575 (7th Cir. 2011)

On January 26, 2011, the Seventh Circuit ruled as valid the Service's application of the six-year statute of limitations, rather than the standard three-year period, to a Son-of-BOSS (Bond and Option Sales Strategy) transaction and the overstatement on a tax return of basis related to the transaction...

Beard v. Comm'r, 2011 U.S. App. LEXIS 1575 (7th Cir. 2011)

On January 26, 2011, the Seventh Circuit ruled as valid the Service's application of the six-year statute of limitations, rather than the standard three-year period, to a Son-of-BOSS (Bond and Option Sales Strategy) transaction and the overstatement on a tax return of basis related to the transaction...

2011 Decisions Impacting IRS Tax Return Investigations

Decisions in two Courts of Appeals in 2011 bear on defining what constitutes an omission from gross income on a submitted return and what limitations period applies to IRS return investigations. Analyses by the Fourth and Seventh Circuits turned in different ways on principles enunciated in COLONY, INC...