According to DoJ, an Aliquippa, Pennsylvania, man was sentenced to 18 Months in Prison for Tax Evasion. According to evidence presented in open court, William Rains failed to timely file his individual income tax returns for tax years 1997, 1999, and 2003-2006. Rains also filed false returns for 2000 and 2001, reporting zero income…
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3rd Circuit in “Bedrosian” Addresses Appellate Standard Of Review In FBAR Penalty Case
March 7, 2018 we posted 1st Taxpayer Victory in a "Willful" FBAR Penalty Case! where we discussed that on September 20, 2017, the Eastern District of Pennsylvania issued an important taxpayer friendly opinion regarding the "willfulness" standard in FBAR penalty matters and In Bedrosian v. United States, Case No. 2:15-cv-05853-MMB (E.D. Pa., Sept. 20, 2017), the court…
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All That You Wanted to Know About Form 706NA – Part II
We previously posted All That You Wanted to Know About Form 706NA - Part I, where we discussed that in the area of estate tax compliance, many of us have prepared Form 706’s, the estate tax return for US citizens and domiciliaries. To be sure, this form is quite voluminous and can take a while…
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Taxpayer Appeals Ct of Claims Ruling Upholding FBAR Penalty in excess of $100,000
The Court of Federal Claims, granted summary judgment in IRS' favor earlier this year, determining that a taxpayer's failure to file a Report of Foreign Bank and Foreign Accounts (FBAR or FinCEN Form 114 was willful and upheld IRS's imposition of a $697, 229 penalty, i.e., an amount greater than the $100,000 maximum set out in regs…
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