United States of America v. Sagoo
Case Number:
4:24-cv-01159
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December 23, 2025
Top Federal Tax Decisions Of 2025
Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.
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September 19, 2025
$1M FBAR Penalty Without Jury Unconstitutional, Judge Says
A woman who faced more than $1 million in civil penalties for failing to report offshore bank accounts to the IRS is off the hook, as a Texas federal court ruled Friday that the federal government violated her constitutional right to a jury trial.
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May 15, 2025
Texan Says IRS' $1M FBAR Penalty Unconstitutional
A Texan urged a federal court to dismiss the U.S. government's suit seeking to collect $1 million in penalties for unreported offshore bank accounts, arguing that the IRS' penalty assessment violated her constitutional right to a jury trial.
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April 24, 2025
Gov't Stands By $1.7M In FBAR Penalties Against Texan
Constitutional law does not stop the U.S. from imposing $1.7 million in penalties against a Texan for failure to report foreign bank accounts, the U.S. told a federal court in arguing against the "myriad" of arguments she has made to dismiss the case.
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March 13, 2025
Texan Calls $1.7M In FBAR Penalties Unconstitutional
Constitutional law bars the United States from imposing $1.7 million in penalties for failure to report foreign bank accounts, a Texan said in urging a federal court to dismiss such an assessment against her.
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November 27, 2024
US Seeks FBAR Penalties Over $1.7M In Foreign Accounts
A Texas woman should face penalties for willfully failing to disclose foreign bank accounts from 2011 through 2013, which held balances exceeding $1.7 million, the U.S. government told a federal court Wednesday.