Taxpayer Seeks SCOTUS Review on $3 Million Foreign Account Spat

A taxpayer who lost a challenge on a $3 million tax bill for failing to report a Swiss bank account is seeking review by the US Supreme Court.

Monica Toth called on the high court to review her April loss in the US Court of Appeals for the First Circuit, arguing that the appeals court erred by breaking from Supreme Court precedent “at a bedrock level” in its view of the excessive fines clause of the Eighth Amendment.

Toth said the high court’s 1993 holding in Austin v. United States—finding that the Eighth Amendment applies to civil forfeiture ...