Texas Judge Says Deadline Missed to Disallow $153 Million Shelter Loss

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A magistrate judge for the U.S. District Court for the Eastern District of Texas finds that Texas billionaire banker Andrew Beal used a Son-of-BOSS tax shelter to create $153 million in artificial tax losses for 2001, but holds that IRS missed its three-year deadline for disallowing the losses. The judge does find that IRS did make the deadline for disallowing Beal's $46.5 million in claimed losses for 2002 from the shelter. The court also finds for the government in regard to IRS's assessment of accuracy-related penalties under tax code Section 6664.