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 ยง 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)