In JCX-75-14, the Joint Committee on Taxation (the JCT) describes the chairman’s mark of the Preserving America’s Transit and Highways Act of 2014, scheduled for markup by the Senate Committee on Finance on June 26, 2014.  The chairman’s mark includes several “pay-fors,” including a provision that would extend the statute of limitations for IRS assessments to six years for substantial understatements of income that result from overstatements of basis, which would effectively overturn the Supreme Court’s holding in Home Concrete & Supply, LLC. v. United States, 132 S. Ct. 1836 (2012).  The markup would also expand minimum distribution rules applicable to employer sponsored tax-favored retirements plans, e.g. 401(k) plans, and to individual retirement arrangements (IRAs).