D.C. Circuit’s First Farhy Opinion Requires Reconsideration

Tax Notes

Jonathan Black authored the article "D.C. Circuit’s First Farhy Opinion Requires Reconsideration" published in Tax Notes on May 21, 2024. 

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Jonathan Black is a tax controversy and litigation attorney and a former advisor to the IRS. He is currently in private practice at the Washington, D.C. office of Caplin & Drysdale.

In this post, Black argues that the D.C. Circuit incorrectly decided Farhy v. Commissioner and that the court should reconsider the case en banc.

For the full article, please visit Tax Notes' website (subscription required) or see the Related Materials tab below. 


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