Supreme Court Excludes Overstatements of Basis From Six-Year Statute of Limitations—But Engenders Uncertainty on Administrative Deference Principles
Author: Alan Horowitz.
Source: Volume 30, Number 01, Fall 2012 , pp.11-18(8)
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Abstract:
The Supreme Court’s decision in United States v. Home Concrete and Supply, LLC has definitively resolved a statute of limitations issue in favor of the taxpayer. However, it failed to clarify many of the broader administrative law issues involved, as the Court could not muster a five-Justice majority for this part of the decision. We can expect more squabbling to come in the lower court.Keywords: United States v. Home Concrete and Supply, LLC; tax; statute of limitations; Chevron deference; Brand X decision; administrative law; Supreme Court
Affiliations:
1: Miller & Chevalier.