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Josh Ungerman was quoted in the Tax Notes article, "Fallout From Farhy on Assessable Penalties Could be Extensive" by Andrew Velarde

Josh Ungerman was quoted today in the Tax Notes article, "Fallout From Farhy on Assessable Penalties Could Be Extensive" by Andrew Velarde. In Farhy v. Commissioner, the Tax Court held that the IRS could not assess penalties under section 6038(b) against a taxpayer for his failure to file Forms 5471, "Information Return of U.S. Persons With Respect to Certain Foreign Corporations." In the article Mr. Ungerman says, "the decision illustrates the extent to which checks and balances of the judicial branch can protect a taxpayer." He continued by also saying, "expect challenges and refund claims relating to IRS section 6038(b) penalties in addition to other penalties that may not be immediately assessable by the IRS in light of the Tax Court's analysis in Fahry."