Case: U.S. Appeals Court Affirms Tax Court’s Dismissal of FBAR Penalty Dispute

The U.S. Court of Appeals for the Eleventh Circuit issued a decision affirming the Tax Court’s dismissal of taxpayers’ petition for review against the IRS’s rejection of their request for a collection-due-process hearing. Taxpayers, a married couple, failed to report foreign bank accounts between 2005 and 2009, resulting in penalties under the Bank Secrecy Act. The IRS began collecting the penalties through administrative offset of the taxpayers’ Social Security benefits. Taxpayers petitioned the Tax Court seeking review of the IRS’s rejection of their request for a collection-due-process hearing. The Court of Appeals held that the Tax Court lacked jurisdiction because: ...