The U.S. Court of Appeals for the D.C. Circuit recently reversed a Tax Court decision which had limited the IRS’s authority to penalize taxpayers for the delinquent reporting of foreign-owned entities. The Farhy case has been intensely followed because it was initiated as a challenge to a longstanding, entrenched policy of the Service to automatically penalize taxpayers for failing to file certain tax forms involving non-U.S. entities.
For more: https://www.wbny.com/Federal-Appellate-Court-Decision-Bolsters-IRS-Authority