Will The Zwerner FBAR Fine Pass Constitutional Muster?

Law360, New York (June 5, 2014, 10:37 AM EDT) -- Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United States 150 percent of the value of his account plus an additional statutory assessment of 12 percent and interest.

Zwerner's account balance was roughly $1.5 million, resulting in a penalty of about $2.5 million. Another hearing is set in the case for June 6, 2014, where the district court will consider how it intends to compute a civil penalty. Zwerner will likely argue that...

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