United States v. Home Concrete & Supply, LLC

Summary

The Court held that IRC §6501(e)(1)(A) does not extend the statute of limitations to six years when a taxpayer overstates the basis of property sold, following Colony, Inc. v. Commissioner. The Court rejected the Government’s argument that a later Treasury Regulation could override Colony under Chevron and Brand X. Justice Kennedy, dissenting, argued that statutory revisions left room for agency deference.