Episode 6: Omission from Gross Income for Purposes of the Six-Year Minimum Period for Assessment

Episode 6: Omission from Gross Income for Purposes of the Si...

Kane & Company, Certified Public Accountants and Advisors

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After it lost court cases on whether a basis overstatement is an omission of gross income for purposes of the longer limitations period, the IRS recently modified treasury regulations to make clear that a basis overstatement can trigger the six-year statute of limitations period. In so doing, the IRS sought to strengthen its position, which has been rejected in the Tax Court and two circuit courts this year.
After it lost court cases on whether a basis overstatement is an omission of gross income for purposes of the longer limitations period, the IRS recently modified treasury regulations to make clear that a basis overstatement can trigger the six-year statute of limitations period. In so doing, the IRS sought to strengthen its position, which has been rejected in the Tax Court and two circuit courts this year.