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United States of America v. Schwarzbaum
Case Number:
9:18-cv-81147
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March 04, 2026
Fla. Court Urged To Toss $19M Tax Fine Decided With No Jury
A U.S.-German citizen asked a Florida federal court to toss a nearly $19.6 million tax penalty assessed by the IRS for failing to report foreign bank account information, telling a judge on Wednesday that he wasn't able to take his case before a jury.
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February 09, 2026
$19M In Foreign Account Penalties Required Jury, Court Told
A U.S.-German citizen who failed to report his foreign accounts to the IRS told a Florida federal court that his $19 million punishment violates his right to a jury trial under a U.S. Supreme Court ruling that curbed the use of in-house agency courts to hand down stiff penalties.
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September 05, 2025
Fla. Magistrate Advises Arrest In $19.6M Foreign Account Case
A Florida magistrate judge recommended an order for the arrest of a dual U.S.-German citizen who has failed to pay about $19.6 million in penalties for undisclosed Swiss bank accounts, holding that imposing additional fines would be "an empty gesture."
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December 06, 2023
11th Circ. Questions Whether $18M FBAR Penalty Is Excessive
The Eleventh Circuit questioned Wednesday whether $18 million in tax penalties against a man who failed to report his foreign bank accounts may have breached the U.S. Constitution's bar on excessive fines, with one judge calling the issue the most serious in the case.
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June 09, 2023
Man Can't Halt Repatriation Of $18M During FBAR Appeal
A dual U.S.-German citizen fighting nearly $18 million in tax liabilities for hiding his foreign bank accounts cannot wait for his appeal to be decided before repatriating his assets to a U.S. bank account, a Florida federal judge ruled Friday.
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May 30, 2023
Dual Citizen Appealing $17.9M Repatriation In FBAR Case
A man with citizenship in the U.S. and Germany is appealing a federal court order calling for him to repatriate $17.9 million to cover a judgment for failing to file reports of foreign bank accounts, according to a notice filed Tuesday in a Florida federal court.
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March 29, 2023
Floridian Ordered To Repatriate $17.9M For FBAR Violations
A Floridian fighting a $17.9 million judgment for hiding foreign bank accounts must transfer enough money from his overseas accounts to cover the debt, a Florida federal judge ruled, rejecting the man's arguments the court lacked authority to order the repatriation.
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January 23, 2023
Floridian Urges Court To Deny Gov'ts $18M Repatriation Bid
A Floridian should be allowed to keep about $18 million overseas while the Eleventh Circuit weighs his appeal against the IRS' penalty calculation for undisclosed Swiss bank accounts, he told a Florida federal court, arguing against the U.S. government's repatriation bid.
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January 06, 2023
Court Urged To OK Seizing Overseas Funds For $18M Penalty
The U.S. should be allowed to seize the overseas funds of a Floridian who moved his assets offshore in the wake of an $18 million penalty for failing to report foreign bank accounts, the U.S. told a Florida federal court Friday.
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October 28, 2022
Fla. Judge OKs $18M In FBAR Penalties Recalculated By IRS
A Florida man owes $18 million in penalties for willfully failing to report his foreign bank accounts after a Florida federal court found that the Eleventh Circuit, which had faulted the IRS' penalty calculation, didn't vacate the court's determination of his culpability.