The U.S. Tax Court ruled recently that the U.S. Internal Revenue Service has no statutory authority to assess (or collect) civil penalties under IRC §6038(b) for failure to file or.
The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related 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.