Carpenter Family Investments LLC v. Comr., 136 T.C. 373 (2011)

(IRS regulatory position that overstated basis of items on tax return are subject to six-year statute of limitations to the extent the omission from gross income exceeds 25 percent of amount reported on return invalidated; court follows prior opinion in Intermountain Insurance Service of Vail LLC, et al. v. Comr., 134 T.C. No. 11 (2010) which invalidated Treas. Reg. Sec. 301.6501(e)-1T; modified regulatory language still rejected on basis that definition of omission from gross income not limited to context of trade or business; 2011 U.S. Supreme Court opinion in Mayo Foundation for Medical Education and Research v. United States applying Chevrondeference to treasury regulations immaterial; three-year statute of limitations of I.R.C. Sec. 6501(a) applicable; IRS final partnership administrative adjustment untimely). 

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