IRS Arbitrarily Calculated $1.5M FBAR Penalty, Court Says

Law360 (May 12, 2020, 7:34 PM EDT) -- The IRS arbitrarily calculated a penalty of over $1.5 million for a woman who failed to file foreign bank account reports, a California federal court has ruled, but she still must prove her failure to file the FBARs wasn't willful.

The Internal Revenue Service used inappropriate data to assess a penalty to Margaret Jones for untimely filing FBARs for 2011 and 2012 for her accounts, the court said. While it granted her motion for summary judgment on that issue, it rejected a separate motion by her and said she will need to establish at trial that she didn't willfully fail to file...

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