Buffington v. Mississippi State Tax Commission

GRAVES, Presiding Justice,

for the Court:

¶ 1. The Buffingtons reached a settlement with the Internal Revenue Service (IRS) regarding additional tax liability assessed by the federal government for previously unreported income. The Mississippi State Tax Commission (MSTC), within three years of being notified by the IRS that the IRS had increased the Buffing-tons’ reported taxable income, issued an assessment to the Buffingtons for the additional amount the Buffingtons owed in state income taxes.

¶ 2. Mississippi Code Section 27-7-49 provides that, when the IRS increases a taxpayer’s reported…