Alon Farhy was not the most sympathetic of taxpayers. That may explain why the D.C. Circuit was inclined to decide against him. He failed — perhaps intentionally — to file several tax forms for 2004 and subsequent years, for which the IRS eventually assessed penalties of nearly $500,000. The Tax Court held in Farhy’s favor, based on an unbiased (albeit incomplete) analysis of the relevant law. On appeal, the D.C. Circuit was apparently incapable of such judicial restraint, deciding against the admittedly noncompliant Farhy after a cursory analysis of what it thought to be the relevant law.
In an article published in Tax Notes Federal, Kevin M. Jacobs, Brendan Sinnott and Kenneth Brewer analyze the decision's impact on tax law interpretation and advocate for fair treatment of taxpayers.
READ THE TAX NOTES ARTICLE
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