Salman Ranch Ltd. v. United States

I respectfully dissent, for the Court of Federal Claims was correct in affirming the action of the Internal Revenue Service in applying the extended six-year period of limitations of 26 U.S.C. (“I.R.C.”) § 6501(e)(1)(A) to the assessment of income tax on the sale of the Salman Ranch.1 The IRS explained that the standard three-year limitations period did not apply because the taxpayer omitted from gross income “an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return.” 26 U.S.C. § 6501(e)(1)(A). The parties stipulated, for the…