Get Even More Visitors To Your Blog, Upgrade To A Business Listing >>

Broad Reading of Six Year Statute of Limitations for Subpart F Omission

Code Sec. 6501(e)(1)(C) extends the normal three-year Statute of limitations on assessment to six years as to omissions of Subpart F income. In a Chief Counsel Advice, the extended six-year period was determined to apply to the entire tax liability of the corporation for that year, not just to the specific subpart F items constituting the gross income omission.

Chief Counsel Advise 202142009



This post first appeared on RUBIN ON TAX, please read the originial post: here

Share the post

Broad Reading of Six Year Statute of Limitations for Subpart F Omission

×

Subscribe to Rubin On Tax

Get updates delivered right to your inbox!

Thank you for your subscription

×