This PodCast provides a look at recent cases where the IRS lost a statute of limations argument. In the case of Bakersfield Energy Partners, LP, 128 TC No. 17, the question was whether an overstatement of basis used in computing a Section 1231 gain could result in omission from gross income that triggers the six year statute of limitations under Code Sections 6629 and 6501. The Tax Court decided the answer was "No".
The materials can be downloaded at http://www.edzollars.com/2007-06-22_Limits.pdf .
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