A federal court has concluded that a suspected "Son of BOSS" transaction that caused an overstatement of basis in the calculation of gain from a sale of real estate is a gross income omission that allows the IRS six years to assess a deficiency The ruling, in Salman Ranch Ltd. v. U.S., adds to the list of several recent lower court rulings that have reached conflicting legal conclusions on similar fact patterns.
The Court of Federal Claims denied the taxpayer's argument that the assessment was subject to the three-year statute of limitations of IRC [section] 6501(a). The court said the six-year extended period of [section] 6501(e)(1)(A) applied because the overstated basis ...