February 12, 2021
Eighth Circuit reverses taxpayer-favorable Tax Court opinion - tax return received by Virgin Islands taxing authorities didn't satisfy couple's US tax filing obligations
Agreeing with the IRS, the Eighth Circuit has reversed the Tax Court's decision in Coffey v. Commissioner (105 T.C. 60) to hold that the taxpayers' filing obligations under the Code were not satisfied by either: (1) the Virgin Islands Bureau of Internal Revenue's sending some of the taxpayers' documents to the IRS or (2) the taxpayers' filing the returns with the Virgin Islands. Because the taxpayers had not filed a return with the United States, they had not satisfied the statute of limitations provisions in IRC Section 6501(a) and therefore could not assert the statute of limitations as a defense to the deficiency notice at issue.