The Tenth Circuit yesterday reversed the Tax Court and held that Reg. § 301.6501(e)-1 is entitled to Chevron deference and concluded that overstated asset basis triggers the six-year statute of limitations. Salman Ranch Ltd. v. Commissioner, No. 09-9015 (10th Cir. May 31, 2011). The Government now has won three of the five appellate cases on this issue. For more, see:
- Miller & Chevalier Tax Appellate Blog, 10th Circuit Sides With Government on Intermountain Issue
- TaxProf Blog, Fed. Cir. Exacerbates Split on Overstatement of Basis, 6-Year SOL (Mar. 12, 2011)
