By David J. Shakow David J. Shakow is counsel in the Philadelphia office of Chamberlain, Hrdlicka, White, Williams & Aughtry and is professor emeritus at the University of Pennsylvania Law School. The Supreme Court’s decision in Home Concrete raises new questions about the deference to be given to administrative pronouncements that conflict with prior judicial [...]
Posted tagged ‘statute of limitations’
A Concrete Show for Brand X?
April 30, 2012Innocent Spouse Relief After Mayo: Congress Strikes Back?
May 2, 2011By David Shakow Following the Supreme Court’s decision in Mayo Foundation v. United States, in which the Court ruled that tax regulations receive deference from courts under the Chevron doctrine that applies to non-tax regulations, many commentators acknowledged the decision’s anticipated impact on disputes about the validity of tax regulations. The new standard gives the [...]
Beard v. Comm’r: Basis Overstatement Is An Omission Of Gross Income
January 27, 2011By Jonathan Prokup The Seventh Circuit handed the government a victory yesterday, deciding in Beard v. Comm’r that a taxpayer’s overstatement of basis can result in an omission of income under Code section 6501(e), thereby extending to six years the statute of limitations for the IRS to make an assessment, rather than the usual three.
How Long Does The IRS Have To Audit Your Return?
June 14, 2010By George W. Connelly People are always asking how long the IRS can wait from the time you file your return to conduct an audit of your income and expenses. The simple, most definitive answer is “it all depends,” so let’s take a look at the rules. The time in which the IRS must conduct its [...]
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
