The Seventh Circuit Court of Appeals overturns the Tax Court holding that a taxpayer’s overstatement of basis in a Son of Boss tax shelter is an omission of income under § 6501(e) triggering the six year statute of limitations.
For commentary on the implications of this opinion visit Tax Appellate Blog.
Read the Opinion:
Beard v. Commissioner, No. 09-3741 (7th Cir. Jan. 26 2011)