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...

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