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&M Tax Policy Quarterly Outlook: Q2 2026
July 31, 2026
Explore the latest global tax policy and controversy developments from Q2 2026.
Featuring expert insights on OECD, Pillar Two, and tax transparency.
ALVAREZ & MARSAL EXPANDS TAX & REGULATORY PRACTICE INTO INDIA
July 30, 2026
Alvarez & Marsal (A&M), a leading global professional services firm, is scaling its global Tax & Regulatory practice into India, reinforcing its position in one of the world's most complex and high-growth markets for international investors and financial institutions.
The EU Tax Omnibus: a major simplification of the EU direct tax framework
July 23, 2026
On 24 June 2026, the European Commission published its “Tax Omnibus” proposal (“Proposal”) — a single proposed Council Directive amending six EU direct tax directives, with an estimated EUR 6.6 billion in annual compliance cost savings.
EU DAC Recast Proposal: What the European Commission’s simplification agenda means for cross-border tax reporting
July 23, 2026
On June 24, 2026, the European Commission published a proposal to recast the Directive on Administrative Cooperation in the field of taxation (DAC) as part of an ambitious tax simplification package designed to simplify existing EU tax rules and reduce compliance for businesses.
