Heckman v. Commissioner

COLLOTON, Circuit Judge.

This appeal involves a tax dispute that turns on the applicable statute of limitations. Thomas Heckman did not report certain gross income on a tax return for 2003 that he filed in August 2004. The Internal Revenue Service issued Heckman a notice of deficiency in July 2010. Heck-man petitioned the tax court, arguing that the deficiency notice was untimely, because the statute of limitations expired three years after the filing of his return. The tax court determined that a six-year statute of limitations applied, and that the notice was therefore timely. The tax court…