Case: Default Judgment for Willful FBAR Penalties Granted (IRC §6651)

The U.S. District Court for the Middle District of Florida granted default judgment against the taxpayer for willful Reports of Foreign Bank and Financial Accounts (FBAR) penalties assessed. The taxpayer, a U.S. citizen and experienced tax preparer, maintained foreign bank accounts in 2016 and 2017 with aggregate balances exceeding $10,000, but failed to report them on FBARs as required. The IRS sent a letter notifying the taxpayer of the FBAR penalties and for demand for payment. The taxpayer was served with a complaint and summons, but failed to answer or respond to the complaint. Upon review for a motion for ...