Taxpayer’s Civil Assessment Challenge Not Barred by Jury Verdict

A Scottsdale man’s 2013 conviction for willfully filing false tax returns doesn’t bar him from collaterally attacking civil penalties assessed over his alleged failure to report foreign bank accounts, a federal court in Arizona said.

Michael Quiel, a venture capitalist, was convicted for willfully filing false tax returns. The jury didn’t return a verdict on charges that he willfully failed to file Reports of Foreign Bank and Financial Accounts, or FBARs, but the government subsequently imposed related civil penalties.

In the present lawsuit seeking to enforce the FBAR penalties, the government moved for partial summary judgment on the question of ...