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ARTICLE · 30 SEPTEMBER 2011

Supreme Court Docket Report - September 27, 2011

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Internal Revenue Service ("IRS") Notice 2000-44 prohibits a form of tax transaction, known as "Son-of-BOSS," that uses a short-sale mechanism to inflate a taxpayer’s basis in a partnership interest shortly before selling the interest.

United StatesLitigation, Mediation & Arbitration
Andrew Tauber
Andrew Tauber
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Originally published September 27, 2011

Keywords: taxation, statute of limitations, limitations period, Son-of-BOSS, federal workers, compensation act, rate of compensation

Today the Supreme Court granted certiorari in two cases of interest to the business community:

  • Taxation—Statute of Limitations
  • Longshore and Harbor Workers' Compensation Act—Rate of Compensation

Taxation—Statute of Limitations

Internal Revenue Service ("IRS") Notice 2000-44 prohibits a form of tax transaction, known as "Son-of-BOSS," that uses a short-sale mechanism to inflate a taxpayer's basis in a partnership interest shortly before selling the interest. The effect of the transaction is to limit the capital-gains tax on the sale. When the government believes that a taxpayer has understated the amount of tax owed, the IRS ordinarily has three years to assess additional taxes. 26 U.S.C. § 6501(a). But when a taxpayer "omits from gross income an amount . . . in excess of

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