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The U.S. Tax Court recently held that the IRS could not collect penalties from a taxpayer, who willfully failed to file IRS Form 5471 (Information…

On April 3, 2023, the Tax Court ruled in Farhy v. Commissioner1 that the Internal Revenue Service (IRS) lacks the authority to assess penalties under Section 6038(b) of the Internal...

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters.  In that case, the taxpayer stipulated that he: ...

US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service IRS could neither assess tax penalties under Internal Revenue Code Section 6038b against Alon Farhy nor collect those penalties via a levy.

Ask parents why they work as hard as they do, and many will answer that it is to give their children a better future. For some, this involves sending their children to foreign countries...

On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, ruling that the Internal Revenue Service (IRS) could neither assess tax penalties under Internal Revenue...

Hundreds of private well users have been reimbursed by the state after spending their own dollars to remediate PFAS contamination. But when tax season rolled around this year, they were mailed 1099 forms, telling them the money they received is...

In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S....

While the court's ruling in Bittner v. U.S. is considered taxpayer-favorable, there are issues to consider as you dig into the findings.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.