Case: Taxpayers Failed to Report Beneficial Ownership in Foreign Bank Account, Statute of Limitations Remained Open (T.C. Memo) (IRC §6051)

Taxpayers failed to properly report Wife’s beneficial ownership in her foreign bank account; accordingly, the period of limitations under I.R.C. §6501 remained open at the time the IRS’s notice of deficiency was issued as Taxpayers never furnished the information that was required to be reported under §6048, the U.S. Tax Court held in a memorandum opinion, sustaining the IRS’s determination of tax deficiencies and penalties against Taxpayers. The documentary evidence in the record established that Wife was the beneficial owner of the foreign bank account during the tax years at issue, the court stated. Wife received distributions and directly ...