A “mere clue” for Sherlock Holmes

January 29, 2013

  • 220 Internal Revenue
  • 220XXI Assessment of Taxes
  • 220XXI(B) Time for Assessment and Limitations
  • 220XXI(B)1 In General
  • 220k4572 k. Effect of Erroneous, False, or Fraudulent Returns.

220 Internal RevenuePlain language of provision of Internal Revenue Code (IRC), establishing six-year limitations period for assessing tax attributable to item omitted from gross income on return, requires something far more than a mere clue that might intrigue Sherlock Holmes; rather, disclosure must be sufficient to indicate what type of item has been omitted and how large or small that item is on the face of the relevant returns.
Home Concrete & Supply, LLC v. United States, 599 F. Supp. 2d 678 (E.D.N.C. 2008)
Suggested by Craig Gustafson, Principal Attorney Editor, Westlaw