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Court Unanimously Overturns Farhy, Finding IRS Has Authority To Assess Penalties

Published: May 3, 2024

Farhy challenged whether the IRS had the legal authority to assess section 6038 penalties. The Tax Court said no, but on appeal, the D.C. Circuit disagreed.

Source: forbes.com

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United StatesSullivan WorcesterEric RietveldSupreme CourtCircuit CourtUnited States CourtTax CourtDc Circuit CourtCircuit Judge PollardInformation ReturnWith RespectCertain Foreign CorporationsAlon FarhyColumbia CircuitAssessable PenaltiesSection 6038Form 5471

IRS Suffers Another Defeat Related To Civil Penalties In Tax Court

Published: April 25, 2024

The question raised in Mukhi was similar to that in Farhy—and the Tax Court wasn’t willing to deviate from that ruling.

Source: forbes.com

Related Topics:

Foreign BankUs CourtUs Tax CourtTax CourtOffice Of AppealsBank SecrecyCourt FindingsTreasury DepartmentAlon FarhyInternal RevenueInformation ReturnWith RespectCertain Foreign CorporationsBank Secrecy ActFinancial AccountsCollection Due ProcessEighth AmendmentExcessive Fines ClauseEighth CircuitFirst CircuitExcessive FinesAlon Farhyv Commissioner Of Internal RevenueMukhiv Commissioner Of Internal RevenueAssessable PenaltiesInformation Returns