Photo: Wrangler via Adobe Stock 'Hyatt Hotels': Are Omissions From Gross Income an Accounting Method?
'Hyatt Hotels v. Commissioner' underscores that even an approach to accounting for income and expenses that has been applied consistently by a taxpayer over many years is not necessarily a "method of accounting" subject to the government's broad power to impose adjustments under Section 481(a).
October 18, 2023 at 12:00 PM
10 minute read
The IRS often determines upon audit that a business has over a period of years failed to report properly items of income or expense. In that case, the ability of the government to assert additional tax with respect to each year under audit is commonly limited by Internal Revenue Code (Code) section 6501, under which tax must generally be assessed within 3 years after the return for the relevant period is filed.
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