Seaview Trading, LLC v. Commissioner, TC Memo 2019-122: faxed tax return to Revenue Officer not a Filed Return, $35 million disallowed deduction time barred

In Seaview Trading, LLC v Commissioner, TC Memo 2019-122, the Tax Court held that a tax return faxed to a revenue officer was not a tax return. Therefore, an IRS adjustment involving a $35 million disallowed deduction was time barred.

See full opinion by clicking Seaview Trading, LLC v. Commissioner, TC Memo 2019-122: faxed tax return to Revenue Officer not a Filed Return, $35 million disallowed deduction time barred.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..

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