American citizens residing in the US Virgin Islands who fail to file their federal income tax returns are not subject to statute of limitations, and can be issued a tax deficiency at any time, the US Tax Court said in a precedent-setting opinion.
David Tice, a US citizen, resided there during the 2002 and 2003 tax years and filed his taxes with the Virgin Islands Bureau of Internal Revenue, but failed to file with the IRS. The agency issued a deficiency in 2015, with additional taxes and penalties. Tice argued that the 3-year period of limitations under tax code Section ...
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