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Tax Court Filing Requirements Internal Revenue Service

BakerHostetler

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

BakerHostetler on

On April 3, 2023, the United States Tax Court issued its opinion in Farhy v. Commissioner of Internal Revenue, which upset long-standing views on how the IRS may assess and collect penalties for failure to file certain tax...more

Gray Reed

IRS Concedes Yet Another Form 3520 Related Penalty Case

Gray Reed on

United States citizens and residents are often not aware of the myriad of foreign information return filing obligations that exist under federal tax laws.  For example, buried within the Code are reporting obligations...more

Sullivan & Worcester

IRS Guidance Provides Critical Information on Extended Deadlines for Returns, Payments and Other Time-Sensitive Tax Actions -...

Sullivan & Worcester on

As reported in our recent Client Alert, the IRS continued its series of tax relief announcements related to the COVID-19 emergency when it issued Notice 2020-23. This alert provides more detailed guidance on IRS Notice...more

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