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Penalties › Tax Court › Reporting Requirements

Littler

Employers Are Obligated to Comply with Tax Law Despite Increase in Frivolous Tax Arguments

Littler on

In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

Baker Donelson on

Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

Holland & Knight LLP

IRS Authority to Assess Certain Foreign Information Return Penalties Restored by D.C. Circuit

Holland & Knight LLP on

The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more

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