Broad Reading of Six Year Statute of Limitations for Subpart F Omission

Code Sec. 6501(e)(1)(C) extends the normal three-year statute of limitations on assessment to six years as to omissions of Subpart F income. In a Chief Counsel Advice, the extended six-year period was determined to apply to the entire tax liability of the corporation for that year, not just to the specific subpart F items constituting the gross income omission.

Chief Counsel Advise 202142009