Taxpayers will pay more penalties and face a greater risk of having to fight the IRS over fines they consider unfounded as a result of a recent D.C. Circuit ruling on foreign holdings.
The decision is a sharp reversal in a tax case that lawyers say could have broad implications in how the IRS collects penalties.
The US Court of Appeals for the D.C. Circuit reaffirmed in a May 3 ruling that the IRS can automatically issue penalties to taxpayers who fail to report foreign holdings, overturning a US Tax Court ruling last year saying the agency lacked authority to ...
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