Big Win for NJ Tax Attorneys Against IRS
IRC Section 6501(e)(1)(A)(ii) provides a six-year statute of limitations if a taxpayer omits from gross income amounts attributable to one or more assets with respect to information required under IRC Section 6038D. Despite the Government's attempt to draw parallels between IRC Section 6038D and previously enacted statues, the Tax Court ultimately determined that the statute being used to assess additional taxes from non-compliant taxpayers with foreign accounts could not be used for tax years prior to 2010 because there was no IRC Section 6038D filing requirement prior to that year. As a result of this ruling, the taxpayer ended up owing no additional taxes. Additionally, this ruling could potentially prevent the Government from collecting millions of dollars from other taxpayers in similar situations, making it a landmark decision for the US Tax Court.
"I'm proud of both Jeffrey and Harvey for their work on this particular case. The ruling is a testament to their proficiency and serves as a prime example of the expertise in
A PDF of the full Tax Court opinion in Rafizadeh v. Commissioner, 150 TC 1 (2018) can be found here.
Jeffrey R. "Jeff" Pittard, Counsel devotes his practice to all areas of estate and wealth preservation and tax planning for high net worth individuals. He is adept at composing estate planning documents, including wills and trusts. In addition, he has handled all aspects of estate tax administration in both
Email: [email protected] Phone: 201-896-4100
Email: [email protected] Phone: 201-896-7708
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