A Recent Tax Court View of Statute of Limitations Provisions

Andrew Roberson and Elizabeth Chao wrote this bylined article on the US Tax Court opinion in Rafizadeh v. Commissioner, which held that the six-year statute of limitations for amounts reportable under Internal Revenue Code Section 6038D applies only to years in which Section 6038D was effective. The authors noted that the opinion “provides insight into the Tax Court’s approach toward interpreting statute of limitations provisions.”