Opinion Analysis: No Six-Year Statute of Limitation on Overstatement of Basis


In this SCOTUSblog post, Alan Horowitz discusses the Supreme Court's decision in United States v. Home Concrete and Supply, LLC, in which it ruled in favor of the taxpayer by a vote of five to four. The result is a definitive resolution of the particular tax dispute before the Court – whether the six-year statute of limitations applies to an overstatement of basis – but a much less definitive resolution of the broader administrative law issue implicated in the case.

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