Andersen Managing Director Joe Calianno's comments are featured in the recent Bloomberg Tax article IRS Win on Foreign Holdings Penalties Seen as Blow to Taxpayers. The article covers the U.S. Court of Appeals for the D.C. Circuit's recent ruling upholding IRS's power to automatically issue penalties to taxpayers who fail to report foreign holdings. The ruling overturned a U.S. Tax Court ruling issued last year holding that IRS lacked the authority to do so. Joe noted that the Tax Court decision is still helpful for taxpayers outside the D.C. Circuit who assert that IRS must first commence a civil action to assess penalties. It is possible that a different circuit court could agree with the Tax Court's analysis and conclusion, Joe added.