Burks v. United States, 633 F.3d 347(5th Cir. 2011)

(IRS position that 6-year statute of limitations specified in I.R.C. Sec. 6501(e)(1)(A) applied to omission of gross income exceeding 25 percent of gross income as a result of overstated basis rejected; three-year statute of limitations applies; court's opinion consistent with opinions from the Fourth, Ninth and Federal Circuit Courts of Appeal and contrary to the Seventh Circuit).