December 23, 2011
Supreme Court Briefing in Home Concrete (6-Year SOL and Overstatement of Basis)
The briefing is now completed in United States v. Home Concrete & Supply, LLC, No. 11-139, which is scheduled for oral argument in the U.S. Supreme Court on Jan. 17, 2012.
- Opinion below (4th Cir. Feb. 7, 2011)
- Issue: (1) Whether an understatement of gross income attributable to an overstatement of basis in sold property is an omission from gross income that can trigger the extended six-year assessment period; and (2) whether a final regulation promulgated by the Department of the Treasury, which reflects the IRS's view that an understatement of gross income attributable to an overstatement of basis can trigger the extended six-year assessment period, is entitled to judicial deference.
- Brief for the United States
- Brief for Home Concrete & Supply, LLC
- Amicus brief of Bausch & Lomb, Inc.
- Amicus brief of Daniel S. Burks and Reynolds Properties
- Amicus brief of Grapevine Imports, LTD
- Amicus brief of Kristin E. Hickman (University of Minnesota Law School)
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