Forbes contributors publish independent expert analyses and insights. Matthew Roberts is a tax attorney who covers tax litigation and fraud.

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form ...

The U.S. Tax Court ruled recently that the U.S. Internal Revenue Service has no statutory authority to assess (or collect) civil penalties under IRC §6038(b) for failure to file or filing late IRS ...

In the recent U.S. Tax Court’s decision in Farhy v. Commissioner 160 T.C, No. 6 (April 3, 2023), the court ruled that the Internal Revenue Service lacks authority to assess and collect penalties from ...