Donald Dewees v. USA
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April 09, 2019
DC Circ. Won't Revive Canadian's FBAR Penalty Refund Suit
A Canadian's due process and equal protection rights were not violated by penalties imposed by the Internal Revenue Service for failing to disclose foreign accounts, the D.C. Circuit said Tuesday in affirming the dismissal of his $134,000 tax refund suit.
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August 27, 2018
Canada Resident Got Due Process, IRS Tells DC Circ.
The fact that an American living in Canada can litigate his tax dispute is proof enough that the Internal Revenue Service gave him due process when it imposed penalties, the agency told the D.C. Circuit in a brief Friday.
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June 27, 2018
DC Circ. Asked To Revive Canada Resident's Tax Penalty Row
An American living in Canada has asked the D.C. Circuit to revive a suit to recover more than $134,000 in penalties, saying the Internal Revenue Service did not give him an adequate chance to contest the penalties.