Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000

Another court just slammed the Internal Revenue Service (IRS), limiting the “willful” FBAR penalty to $100,000. Another taxpayer victory took place last week in United States v. Wadhan, (Civil Action No. 17-CV-1287-MSK District Court, District of Colorado July 18, 2018). The Wadhan’s failed to file or filed inaccurate so-called FBARs for 2008, 2009, and 2010. … Continue reading Second Court Bars IRS from Assessing FBAR “Willful” Penalty in Excess of $100,000 →

FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge”

I blogged recently about the fact that mounting court cases have given the stamp of approval for the Government to meet a lower “burden of proof” in demonstrating that a taxpayer “willfully” failed to file an FBAR. The “burden of proof” refers to which party is responsible for putting forth evidence and, the level of evidence … Continue reading FBAR “Willful” Penalty: New Case, Taxpayer “Charged With Knowledge” →