Overview
Bloomberg BNA quoted Walker Johnson in a June 3 article titled “IRS Won’t Always Follow Lower Court Interpretations of Code.” The article discusses changes by the IRS to its interpretation of tax code provisions. In United States v. Home Concrete & Supply, LLC, the US Supreme Court found that the existing statute did not provide the IRS the authorization to include an overstated investment or basis in the actions covered by the six-year limitations period instead of the three-year period.
Mr. Walker tells Bloomberg BNA that the Supreme Court says the IRS could not apply an interpretation different from the high court's “unless Congress told you otherwise.”
The full article can be read at Bloomberg BNA (subscription required).