Supreme Court Excludes Overstatements of Basis from Six-Year Statute of Limitations - But Engenders Uncertainty on Administrative Deference Principles

Journal of Taxation of Investments
09.05.12
In this article, Alan Horowitz discusses the recent Supreme Court decision in United States v. Home Concrete and Supply, LLC, which definitively resolved a statute of limitations issue in favor of the taxpayer. The ruling, however, has raised more questions than it answered on the broader administrative law issues that were implicated in the case and we can expect more discussion on these issues in the lower courts.
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