In the case of Toso, et al v. Commissioner, 115 TC No. 4, the Tax Court considered issues related to passive foreign investment company (PFIC) gains.  Specifically, the Court looked at how gains taxed under the rules of IRC §1291(a) will be counted for purposes of determining if there is a substantial omission from gross income under IRC §6501(e)(1)(A)(i) that would allow for a six-year statute of limitations.

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