Feature Article 
How to Handle Foreign Informational Form Penalties
It was approximately two years ago when the tax law equivalent of a 7.0 earthquake came in the form of a decision from the United States Tax Court when it issued its decision in the case of Farhy v. Commi... David Woods, EA, USTCP, NTPI Fellow®
Fall 2025,
Feature Article,
collection due process, §6038, §6751(b), Form 8938, §6330, Form 926, Form 5471, Form 8865, Form 3520, Form 5472, §6201(a), Farhy v. Commissioner, §6038(a), §6038(b), Mukhi v. Commissioner, §6038(c), Safdieh v. Commissioner, first-time abatement, foreign informational form penalty
Tax Court
Say Goodbye to Most Form 5471 Penalties
Alon Farhy used two Belize corporations to attempt to evade United States income tax. While he was not prosecuted for these actions, he also never filed Form 5471, Information Return of U.S. Persons With Respect to Certain Fore... Thomas Gorczynski, EA, USTCP