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US Tax Court issued opinion in Farhy v. Commissioner, holding that the Internal Revenue Service IRS lacked statutory authority to both assess tax penalties under Internal Revenue Code Section 6038b and collect said penalties via a levy against the taxpayer.
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...
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax...
The recent Tax Court decision is favorable to taxpayers with certain interests in foreign corporations.
The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information...