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Expert Analysis

A Recent Tax Court View Of Statute Of Limitations Provisions

By Andrew Roberson and Elizabeth Chao ( 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....

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