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09-3741 Beard v. CIR

Tax Income tax; statute of limitations An overstatement of basis can be treated as an omission from gross income, triggering a six-year statute of limitations. “[A] plain reading of Section 6501(e)(1)(A) would include an inflation of basis as an omission of gross income in non-trade or business situations. See Regions Hospital v. Shalala, 522 U.S. 448, 467 (1997); ...

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