Testing the Limits-The IRS Loses Statute of Limitations Case

This week we look at recent cases where the IRS lost a statute of limations case.  In the case of Bakersfield Energy Partners, LP, 128 TC No. 17, the question was whether an overstatement of basis used in computing a Section 1231 gain could result in omission from gross income that triggers the six year statute of limitations under §6629 and §6501.   The Tax Court decided the answer was no.The materials can be downloaded at http://www.edzollars.com/2007-06-22_Limits.pdf .The podcast is sponsored by Leimberg Information Services, located on the web on http://www.leimbergservices.com .