Alon Farhy v. Cmsnr. IRS

  1. July 08, 2024

    Top International Tax Cases Of 2024: Midyear Report

    With a U.S. Supreme Court decision affirming a key 2017 tax provision on repatriation, millions of dollars in FBAR penalties upheld and a French ruling confirming the U.S. government's access to foreign bank accounts, the IRS stacked up important court victories on international enforcement in the first half of 2024. Here, Law360 reviews those and other significant rulings from the past six months.

  2. June 14, 2024

    Full DC Circ. Won't Hear Foreign Disclosure Penalty Dispute

    The D.C. Circuit declined to reconsider its ruling overturning a major U.S. Tax Court decision that had crimped the administrative collection arm of the Internal Revenue Service, letting stand a panel's restoration of the agency's power to more freely penalize undisclosed foreign corporations.

  3. June 04, 2024

    Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties

    A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.

  4. 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.

  5. 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.

  6. 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.

  7. 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.

  8. 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.

  9. 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.