In Intermountain, the Court of Appeals for the District of Columbia has reversed the Tax Court and upheld the regulations for Code section 6501(d)(1)(A) that treat a basis overstatement as triggering the 6 year limitations period for when a taxpayer omits from gross income an amount that is greater than 25% of the amount of gross income stated in the return.
In upholding the regulations, the DC Court of Appeals joins the Court of Appeals for the Federal Circuit and the Courts of Appeals for the Seventh and Tenth Circuits. The Fourth and Fifth Courts of Appeals have struck down the regulations.
Margaret L. Cross-Beliveau, Esq., LL.M.
The Beliveau Law Group: Massachusetts | Florida | New Hampshire
The attorneys at The Beliveau Law Group provides legal services for estate planning (wills and trusts), Medicaid (planning and applications), probate (estate and trust administration), business law (formation and operation), real estate (residential and commercial), taxation (federal and state), and civil litigation (in connection with these practice areas). The law firm has offices and attorneys in Naples, Florida; Boca Raton, Florida; Danvers, Massachusetts; Waltham, Massachusetts; Quincy, Massachusetts; Manchester, New Hampshire and Salem, New Hampshire.