Penalties for Late Filed Forms 3520, 3520-A, 5471, and 5472

In episode 58 of How Tax Works, Matt Foreman discusses Zhang v. IRS, No. 4:24-cv-08210 (N.D. Cal. 2026), which held that the IRS does not need to file a civil lawsuit to impose penalties for a late-filed Form 3520. Zhang is a related case to Farhy, and applies the same principles to penalties for late- or non-filed Forms 3520-A, 5471, and 5472 How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxatio...