Reckless Conduct Can Be Willful FBAR Failure, 2nd Circ. Says

By Kevin Pinner · January 7, 2026, 6:24 PM EST

The standard for willful failure to report foreign bank accounts includes reckless conduct, and a 6% late payment penalty is mandatory for a couple who neglected fines for stashing millions in...

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Case Information

Case Title

United States of America v. Reyes

Case Number

24-2333

Court

Appellate - 2nd Circuit

Nature of Suit

 

Date Filed

September 05, 2024