Tax Court Holds IRS Period Of Limitations Was Untimely

Law360, New York (January 2, 2018, 7:19 PM EST) -- The U.S. Tax Court held Tuesday that a six-year period of limitations for omitting income attributable to certain foreign financial assets is effective only for tax years when the reporting requirement was in effect.

The court found the IRS' notice of deficiencies regarding a taxpayer’s failure to report income on a foreign account for tax years 2006, 2007 and 2008 was untimely because IRC § 6038D, which imposed reporting requirements with respect to “specified foreign financial assets,” went into effect after March 18, 2010. 

The Internal...
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