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

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.

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