Case: Motion to Amend Complaint to Present New Issue Six Years Later Denied (T.C. Memo) (IRC §7453)

Motion to amend a complaint, where the original issue was already decided, more than six years after filing denied as no explanation for the delay was provided and a considerable burden would be placed on the government and the court likely greater than if the new issue was raised in the initial complaint, the U.S. Tax Court held in a memorandum opinion. Taxpayer’s case was settled on a particular issue in 2022. Taxpayer filed a motion to amend the original complaint that was filed six years earlier to introduce a new issue, the allowance of a research tax credit claimed ...