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 8938
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 Penalties