Case: Taxpayer Unable to Raise Statute of Limitations, Laches Defenses in Action to Pierce the Corporate Veil (S.D. Iowa) (§6502)

Taxpayer, an individual member of an LLC, did not raise viable statute of limitations or laches defenses in an action to pierce the corporate veil and collect the LLC’s tax liability from Taxpayer, a district court held, granting the IRS’s motion to strike Taxpayer’s affirmative defenses. The LLC that Taxpayer was a member of improperly claimed tax credits and subsequently distributed all its assets to Taxpayer and its other members. The IRS reduced a tax assessment against the LLC to a judgment and sought to recover from the individual members through actions to pierce the corporate veil, arguing that the ...