New Appeals and Decisions on Two Cases: Alon Farhy and Charles Moore!
Photo by Michael Block: https://www.pexels.com/photo/colorful-cliffside-village-3225528/ It has been another exciting 1st half of a year where the tax community was awaiting with baited breath the Supreme Court's decision on not one but two important course cases! These were the Treasury's appeal on Farhy v. Commissioner and Moore v. United States. Quick recollections on the cases: The first one, Farhy v. Commissioner, Alon Farhy had businesses in Belize for which he had failed to file Forms 5471, Information Return of U.S Persons With Respect to Certain Foreign Corporations, for tax years 2003 through 2010. He had also admitted that these corporations he owned were part of an illegal scheme to reduce his U.S tax burden. He successfully argued with the Tax Court that the IRS could not enforce penalties under §6038 due to a lack of authority. This case was exciting because it would have had far-reaching consequences on the IRS' ability to assess penalties not only o
