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 taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

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