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Section 6501(e)

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Supreme Court Finds No Extended Limitations Period for Basis Overstatement

By Jeffrey H. Schechter on May 1, 2012
Posted in Income Tax, Legislation

The U.S. Supreme Court recently held that an overstatement of basis did not trigger the extended six-year statute of limitations assessment period under Internal Revenue Code Section 6501(e)(1)(A) (United States v. Home Concrete & Supply LLC, U.S., No. 11-139, 4/25/12).

The Court in a 5-4 split decision affirmed a U.S. Court of Appeals for the…

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