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Internal Revenue Code (IRC) Failure-to-File Tax Court

Mayer Brown

Relieved Taxpayers: US Tax Court Reaffirms that IRS Cannot Assess Failure-to-file Penalties

Mayer Brown on

Every parent remembers when their child learns the meaning of the word “no.” That moment often comes as a shock because, up until that moment, most children are models of obedience and unconditional trust. When children learn...more

Freeman Law

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

Freeman Law on

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters.  In that case, the taxpayer stipulated that he:  (1) had Form 5471 filing obligations...more

Fox Rothschild LLP

Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

Fox Rothschild LLP 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 taxpayer failed to file Forms 5471 reporting his interest...more

Freeman Law

Tax Court in Brief | Kemegue v. Comm'r | Additions to Tax for Failure to File

Freeman Law on

Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an addition to tax for failure to pay pursuant to section 6651(a)(1) and (2). During 2017 Kemegue lost his job and experienced multiple...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

McDermott Will & Emery on

We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

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