USA v. Sagoo

  1. October 22, 2026

    5th Circ. Orders New Look At IRS' Loss On FBAR Jury Rights

    A Texas federal court must revisit its 2025 ruling that the IRS violated a woman's jury-trial rights by imposing a $1 million civil penalty for failing to report foreign bank accounts, the Fifth Circuit said, ordering another review in light of a U.S. Supreme Court decision.

  2. October 07, 2026

    Justices' Ruling Has No Bearing In FBAR Case, 5th Circ. Told

    The U.S. Supreme Court's decision upholding federal fines against wireless giants has no bearing on the government's appeal to reinstate the IRS' $1 million penalty against a woman for failing to follow her foreign bank account reporting obligations, she told the Fifth Circuit.

  3. September 28, 2026

    High Court Ruling Requires FBAR Case Redo, 5th Circ. Told

    The U.S. government asked the Fifth Circuit to vacate and remand a Texas federal court's decision that struck down the IRS' $1 million penalty assessment over a woman's undisclosed foreign bank accounts, saying that a June U.S. Supreme Court decision conflicts with the trial court's ruling.

  4. January 26, 2026

    Justices' FCC Review Could Reshape IRS Penalty Disputes

    The U.S. Supreme Court's upcoming review of a pair of cases questioning the validity of the Federal Communications Commission's penalty authority could have ripple effects that further delineate the Internal Revenue Service's authority to impose penalties.

  5. January 02, 2026

    Top Federal Tax Cases To Watch In 2026

    The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.

  6. December 23, 2025

    Top Federal Tax Decisions Of 2025

    Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.