A Recent Tax Court View Of Statute Of Limitations Provisions

Law360, New York (February 9, 2018, 1:05 PM EST) -- On Jan. 2, 2018, the U.S. Tax Court issued an opinion in Rafizadeh v. Commissioner,[1] holding that the six-year statute of limitations for amounts reportable under Internal Revenue Code Section 6038D applies only to years in which Section 6038D was effective.

Section 6038D requires individuals to attach certain information regarding specified foreign financial assets to their tax returns. Section 6038D's reporting requirements do not apply to amounts under $50,000 or to assets for which the IRS provides exceptions under Code Section 6038D(h)(1), including assets that might be subject to duplicative reporting.

In Rafizadeh v. Commissioner, the taxpayer owned a foreign account...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.


  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!

TRY LAW360 FREE FOR SEVEN DAYS

Related Sections

Law Firms

Government Agencies