Last April, in Farhy v. Commissioner, the Tax Court held that the IRS did not actually have authority to assess penalties under IRC § 6038. The result was devastating
Continue Reading What’s Next for International Reporting Post-Farhy?Form 5471
Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties
By Meeren Amin on
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the…
Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting PenaltiesInternal Revenue Service Announces Sweeping Penalty Relief for 2019, 2020 Tax Returns
By Matthew D. Lee on
By Matthew D. Lee and Jonathan Wasser
The Internal Revenue Service plans to provide widespread penalty relief for the late filing of certain tax and information returns for the 2019…
Continue Reading Internal Revenue Service Announces Sweeping Penalty Relief for 2019, 2020 Tax ReturnsTax Court Rejects Taxpayer’s Reasonable Cause Defense for Failure to File Forms 5471
By Matthew D. Lee on
On January 30, 2017, Judge Goeke of the United States Tax Court issued an opinion rejecting a taxpayer’s asserted reasonable cause defense for failure to file Forms 5471, which are…
Continue Reading Tax Court Rejects Taxpayer’s Reasonable Cause Defense for Failure to File Forms 5471