2nd Circ. Reverses Tax Court Ruling In Late Filer's Favor

Law360 (April 2, 2019, 8:07 PM EDT) -- The Second Circuit unanimously overturned a U.S. Tax Court decision that had denied a retired Connecticut woman her tax refund, saying Tuesday that the ruling had resulted in differential treatment of taxpayers that Congress had intended to avoid.

People who file a tax return before receiving a deficiency notice are usually allowed to go back three years before the notice was mailed to them to seek a refund or credit of overpaid income taxes. Those who do not file a return before receiving a deficiency notice were restricted to a two-year look-back period until 1997, when Congress enacted language permitting a...

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