Yesterday, a District Court Judge in Connecticut ruled in favor of our client at summary judgment and found that the non-willful penalty for failure to file an FBAR is capped at $10,000 per form, not per account, as had been argued by IRS and and DOJ. This was a matter of first impression for the Court and the ruling will impact many taxpayers. To date, the issue had only been decided by two other courts and they were divided on the issue.
You can read the decision here: United States v. Kaufman
Questions about this or other tax litigation matters? Contact us at either firstname.lastname@example.org or (203) 285-8545.