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$700,000 Penalty Upheld for Willful Failure to Report (1)

March 22, 2021, 3:48 PMUpdated: March 22, 2021, 5:22 PM

The IRS was justified in imposing a nearly $700,000 penalty against a foreign bank account holder because evidence supported finding that the holder willfully failed to disclose the account, the Federal Circuit ruled.

Alice Kimble argued that she hadn’t willfully violated the Bank Secrecy Act by failing to file a Report of Foreign Bank and Financial Accounts (FBAR) for a Swiss bank account because she didn’t actually know she was obligated to do so. But the U.S. Court of Appeals for the Federal Circuit wasn’t swayed, ruling on Monday that taxpayers who sign their tax returns can’t ...