In Rafizadeh v. Commissioner, 150 T.C. No. 1, the Tax Court issued an important decision for the taxpayers, holding that the six-year statute of limitations with respect to income attributable to certain “specified foreign financial assets”, is effective only for those tax years to which the reporting requirement was applicable and in effect.
IRS Updates List of Designated Private Delivery Services for Timely Mailing Rule
The government shutdown, which went into effect on Tuesday, October 1, 2013, impacts many tax cases, which are in litigation status and are currently pending in the United States Tax Court, as well as those cases, which have a deadline for filing a Tax Court petition to protest an IRS Notice of Deficiency or Notice of Determination.