SCOTUS: 6-Year Statute of Limitations Does Not Apply to Overstatement of Basis

In a huge win for the taxpayers in this case and many other similarly situated taxpayers, the U.S. Supreme Court handed down its opinion in United States v. Home Concrete & Supply, LLC, 2012 U.S. LEXIS 3274 (U.S. Apr. 25, 2012) . The Supreme Court affirmed the decision of the 4 th Circuit Court of...

IRS Queasiness Over the Reaches of Allen

I have recently blogged on the issue of whether the fraud of some person other than the taxpayer signing the return which makes the return fraudulent allows the IRS an unlimited statute of limitations under Section 6501(c)(1), here . I list below the blogs that deal with that issue. In Allen v. Commissioner...

Statutes of Limitations for FBAR Noncompliance Related to Tax Noncompliance

A person commenting on an earlier blog asked the following question (modified slightly for clarity): Does the statute of limitations for the FBAR penalty (both civil and criminal) toll if the taxpayer is outside the U.S.? I answered at least the criminal part of the question in a comment reply...

The Scariest Tax Form? Scary Is in the Eye of the Beholder

Robert Wood has a timely reminder that certain forms, if not filed or filed properly, can create major statute of limitations problems for U.S. taxpayers. Robert W. Wood, Scariest Tax Form? Skip It, And IRS Can Audit Forever (Forbes 3/l3/14), here . The particular form he focuses on is the Form 5471...