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U.S. TAX COURT RULING: IRS LACKS AUTHORITY TO ASSESS PENALTIES UNDER SECTION 6038(b)
On April 3, 2023, the United States Tax Court (“Tax Court”) issued a decision in Farhy v. Commissioner, 160 T.C. No. 6 (April 3, 2023) in which it determined that the Internal Revenue Service (“IRS”) does not have the statutory authority to assess penalties imposed by Section 6038(b) of the Internal Revenue Code (the “Code”). …