Taxing Lessons Case Summaries

Case — Statute of Limitations — Federal Excise Tax (ESOP)

NOTE: On October 1, 2014, the tax court reversed itself and vacated its decision in this case. See 143 T.C. No. 13 (Eggertsen). (The link opens a pdf document on the tax court website.) THE QUESTION Did the statute of limitations expire for imposing an excise tax on an employee stock ownership plan? THE DISPUTE Taxpayer Says: The IRS is barred…

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Taxing Lessons From Court Decisions

Decisions — Reversals and Updates

Back in November 2011, Taxing Lessons featured the City Wide Transit tax court decision (T.C. Memo. 2011-279). In that case, the question was whether the usual three year statute of limitations applied in a situation where the taxpayer’s accountant filed fraudulent returns to cover his embezzlement of payroll taxes. The court decided for the taxpayer and barred the IRS from…

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