The Internal Revenue Service (IRS) and the U.S. Department of
the Treasury recently finalized Treas. Reg. §
301.6501(c)-1(g), which interprets § 6501(c)(10)'s
extended limitations period (and other associated rules) where a
taxpayer fails to disclose a listed transaction. The Regulation
takes an expansive view of the statute and underscores the
importance of complying with disclosure requirements applicable to
"listed transactions."
Overview
Under § 6501(a), the IRS generally has three years from the
date a tax return is filed to assess additional tax. For example,
if an individual who is a calendar-year taxpayer files his or her
2014 income tax return on April 15, 2015, the IRS has until April
15, 2018, to assess any additional tax owed with respect to 2014.
Section 6501(c) contains 11 exceptions, including §
6501(c)(10), that either extend the limitations period or keep it
open indefinitely. For instance, if a taxpayer files a false
return, willfully attempts to
