25% of gross income before COGS i.e. Gross Receipts.

This example illustrates how the 25% Gross Income (GI) threshold is calculated for the 6-year statute of limitations (S/L) under tax law. The IRS extends the statute of limitations from 3 years to 6 years if a taxpayer omits more than 25% of their gross income from their return.

Breakdown of the Calculation:

  1. Gross Receipts: $300,000
  2. Cost of Goods Sold (COGS): ($200,000)
  3. Net Business Income: $100,000
  4. Capital Gains: $40,000
  5. Total Gross Income: $140,000

For the 25% threshold determination, the IRS considers gross receipts plus capital gains, but not net business income:

  • Gross Receipts: $300,000
  • Capital Gains: $40,000
  • Gross Income for 25% threshold: $340,000

Key Takeaways:

  • Capital gains are included in gross income, but only the gain amount, not the total sale proceeds.
  • If a taxpayer omits more than 25% of this $340,000 (i.e., $85,000 or more), the IRS can apply the 6-year statute of limitations for audits.

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