Farhy v. Commissioner Summary
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…
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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...