2nd Circ. Urged To Rethink IRS Win In Foreign Reporting Case

By Natalie Olivo · April 14, 2026, 2:19 PM EDT

A New York business owner asked the Second Circuit to rethink a panel's decision that held the IRS could automatically assess and administratively collect certain foreign information reporting penalties, arguing that...

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Documents

Petition

Case Information

Case Title

Safdieh v. Commissioner of Internal Revenue

Case Number

Court

Appellate - 2nd Circuit

Nature of Suit

Date Filed

March 04, 2025

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