Taxpayer Can't Duck Hidden Foreign Bank Accounts Case

Law360, New York (October 6, 2017, 3:35 PM EDT) -- A Washington federal judge on Thursday declined to toss the U.S. government's suit accusing a man of willfully failing to disclose foreign bank accounts, finding that the allegations could reasonably lead the court to infer that the man understood IRS reporting requirements.

In denying Jeffrey P. Pomerantz's motion to dismiss the case, U.S. District Judge Marsha J. Pechman found that the government had alleged enough to allow the court "to draw the reasonable inference" that Pomerantz willfully failed to report his accounts with the Canada Imperial Bank of Commerce to the Internal Revenue Service in a Foreign Bank and Financial Accounts...

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