Tag: willful penalty

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 →

Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty

The Internal Revenue Service (IRS) must be fuming over the recent court decision in United States v. Colliot (W.D. Texas, Austin Division, Case No. AU-16-CA-01281-SS).  The case was initiated by the US Government to reduce to judgment outstanding civil penalties assessed against Ms. Colliot for her “repeated and willful failures to timely file” an FBAR for the … Continue reading Court Slams IRS: Can’t Assess More Than $100,000 “Willful” FBAR Penalty →