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
A View on the Autumn Budget 2025
November 26, 2025
See the latest commentary from our team of tax experts in relation to the UK Autumn Budget 2025.
Thailand’s 2025 FDI Outlook: Quick Big Win Plan and Data Center Policy Updates
November 26, 2025
Discover Thailand’s foreign direct investment (FDI) outlook in 2025, the government’s “Quick Big Win” initiative, and recent updates to data center project requirements.
Mexico’s 2026 Customs Law: Key Changes for Global Trade
November 25, 2025
Discover the key updates in Mexico's 2026 Customs Law, including changes to customs brokers, import documentation, penalties, IMMEX, and Strategic Bonded Facilities.
Tax alert: 2025 Update to the OECD Model Tax Convention - Global Mobility and Beyond
November 21, 2025
On 19 November 2025, the OECD released the 2025 update to the OECD Model Tax Convention (OECD MTC), introducing significant enhancements aimed at improving tax certainty and providing clearer rules for governments, taxpayers and advisers around the globe.
