Can the IRS Assess a Form 3520 Penalty in 2026?
Can the IRS assess a Form 3520 penalty without going to court? Yes. In Zhang v. IRS (N.D. Cal., May 4, 2026), the court held that Internal Revenue Code section 6039F gives the IRS direct assessment authority for a late Form 3520, meaning the form 3520 penalty lands on your account first and you must…




