David R. Aronson v. Commissioner of Internal Revenue

This is an appeal from a decision of the United States Tax Court, Howard A. Dawson, J., finding that the statute of limitations did not bar assessment and collection of certain deficiencies by the Internal Revenue Service (IRS).

The relevant facts, substantially taken from the Tax Court opinion, are as follows. In 1983, taxpayer David R. Aronson’s 1980 and 1981 income tax returns were audited by the IRS. On the returns, Aronson (taxpayer) had claimed deductions for investments in commodities straddle transactions — $130,000 in 1980 and $284,000 in 1981. During a meeting with the IRS in the…