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A recent Notice of Deficiency from the IRS has received national attention, both for its timing and its recipient. The Notice was directed to Sumner Redstone, the 89-year-old majority shareholder of CBS and Viacom, for failure to file a gift tax return pertaining to a gift made in 1972. The amount of the taxes and penalties total $1.1 million. This does not include interest, which many have calculated going back to only 1996, is at least $1.4 million.
Generally, a statute of limitations applies to deficiencies this old, but because no return was ever filed, the time period did not begin running. On that basis, the Notice was issued, and Redstone is challenging the assessment in Tax Court. He argues that the 1972 payment was in fact not a gift, but was for the settlement of a legal dispute within the family’s movie theater business.
The case is titled Redstone v. Commissioner, T.C., No. 008097-13.