Courts Split on Limitations Period for Substantial Omissions of Income by Partnerships

[Editor's Note: This narrative is derived from Tax Planning for Partners, Partnerships, and LLCs, § 15.01[17][b]] [Editor's Note 2: On September 27, 2011, the Supreme Court granted certiorari in Home Concrete & Supply LLC v. United States, a 4th Circuit Court of Appeals decision that...

Courts Split on Limitations Period for Substantial Omissions of Income by Partnerships

[Editor's Note: This narrative is derived from Tax Planning for Partners, Partnerships, and LLCs, § 15.01[17][b]] [Editor's Note 2: On September 27, 2011, the Supreme Court granted certiorari in Home Concrete & Supply LLC v. United States, a 4th Circuit Court of Appeals decision that...

SCOTUS Oral Argument: Does Overstated Basis = Omission from Gross Income?

Editor's Note: View blog discussion on this site of, and hyperlink to, the January 17th oral arguments before the Supreme Court : SCOTUS Showdown: Oral Arguments Heard in Home Concrete Case ... For some time now, the tax bar has been wringing its hands with frustration over when, and under what...

SCOTUS Showdown: Oral Arguments Heard in Home Concrete Case

On January 17, 2012 before the U.S. Supreme Court, Deputy Solicitor General Malcolm Stewart and Gregory Garre , partner at Latham & Watkins, LLP presented oral argument in United States v. Home Concrete & Supply, LLC, et al. In broad terms, at issue is whether the IRS has three years, or six...