This week we look at recent cases where the IRS lost a statute of limations case.  In the case of Bakersfield Energy Partners, LP, 128 TC No. 17, the question was whether an overstatement of basis used in computing a Section 1231 gain could result in omission from gross income that triggers the six year statute of limitations under §6629 and §6501.   The Tax Court decided the answer was no.

The materials can be downloaded at http://www.edzollars.com/2007-06-22_Limits.pdf .

The podcast is sponsored by Leimberg Information Services, located on the web on http://www.leimbergservices.com .

The IRS this past week issued Notice 2007-54 which grants partial relief from some of the changes made to the preparer penalties under Section 6694(a), delaying full implementation of the provisions until next year.  We discuss the extent of the relief granted, as well as some of the reactions to this change that I've noticed in online discussion groups.

The materials for this podcast, including the above notice, can be found at www.edzollars.com/2007-06-15_Delay_of_Game.pdf .

The podcast is sponsored by Leimberg Information Services, located at http://www.leimbergservices.com .

We further analyze the new law, this time looking in detail at the preparer penalty provisions and the change in the trigger for where the preparer penalty under Section 6694(a).

The materials are available at www.edzollars.com/2007-06-02_Preparer_Penalty.pdf .

The podcast is sponsored by Leimberg Information Services, on the web at http://www.leimbergservices.com .