Alon Farhy v. Cmsnr. IRS
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May 03, 2024
IRS Can Assess Foreign Info Disclosure Penalty, DC Circ. Says
The D.C. Circuit on Friday overturned a major U.S. Tax Court ruling that had struck down the Internal Revenue Service's authority to assess and administratively collect penalties from taxpayers for failing to file an information return on their interests in a foreign corporation.
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January 18, 2024
Broad Reading Of Law Lets IRS Collect Penalty, DC Circ. Told
A businessman's $400,000 penalty for failing to report his foreign enterprises should be reinstated after the U.S. Tax Court wrongly determined that the Internal Revenue Service could not collect the penalty, the U.S. told the D.C. Circuit.
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January 01, 2024
Federal Tax Cases To Watch In 2024
The fates of unrealized income under the U.S. Constitution and the Internal Revenue Service's rulemaking authority under Chevron deference are hot-button tax topics in cases pending before the U.S. Supreme Court. Here, Law360 runs down some of the top federal cases tax experts will be keeping a close eye on in 2024.
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December 21, 2023
Top Federal Tax Cases Of 2023
IRS procedures played a key role in tax-related litigation this year, with the U.S. Supreme Court affirming a decision to allow agency summonses for a law firm's banking records and the Sixth Circuit tossing aside a prior decision vacating an IRS enforcement notice. Here, Law360 reviews some of the most significant federal tax decisions of 2023.
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December 07, 2023
IRS' Foreign Penalty Power Rightly Curtailed, DC Circ. Told
A businessman who persuaded the U.S. Tax Court to declare the IRS powerless to unilaterally collect foreign-business reporting penalties asked the D.C. Circuit to let the decision stand, saying the agency is trying to regain its authority through an inapplicable part of the tax code.
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November 14, 2023
Tax Court Misinterpreted IRS' Authority, Agency Tells DC Circ.
The U.S. Tax Court erroneously held that the Internal Revenue Service lacks the authority to collect penalties from taxpayers who fail to report their foreign businesses, the IRS told the D.C. Circuit.