In BASR Partnership v. United States, the United States Court of Appeals for the Federal Circuit held that the suspension of the three-year statute of limitation to assess tax in section 6501(c)(1) for fraud does not apply when the only intent to evade tax is held by an attorney/promoter of the taxpayer where the attorney/promoter’s actions were not authorized by the taxpayer/client.  The court stressed:  “Importantly, we need not decide whether the term “taxpayer,” as used in § 6501(c)(1), can be interpreted to encompass the actions of a taxpayer’s authorized agents.  The government does not allege—nor under the undisputed facts could it allege—that Mayer acted as an authorized agent of BASR or the Pettinatis in connection with the filing of the tax returns at issue here.”