High Court Trims IRS Window For Targeting Tax Offenses

Law360, New York (April 25, 2012, 6:06 PM EDT) -- The Internal Revenue Service has three years — not six — to go after taxpayers who understate their earnings by overstating costs associated with property sales, a split U.S. Supreme Court held Wednesday, in a win for a company targeted for using a forbidden tax shelter that has been at the center of a high-profile criminal case.

The 5-4 ruling held that a six-year limit available to the IRS under 26 USC §6501(e)(1)(A) in cases of egregious under-reporting of income does not apply to the reporting...
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