Beard v. Comr., 633 F.3d 616 (7th Cir. 2011), rev'g, T.C. Memo. 2009-184

(overstatement of basis in ownership interests of taxpayer's companies constitutes an omission of income under I.R.C. Sec. 6501(e) resulting in a six-year (rather than three year) statute of limitations; IRS Final Regulations (eff. Dec. 14, 2010) upheld).