In United States v. Isac Schwarzbaum, No. 9:18-cv-81147, the U.S. District Court of the Southern District of Florida found the taxpayer liable for nearly $13M in penalties for his willful failure to file FBARs for 2007 through 2009.
As usual
Latest from Law Office Of Kunal Patel PLLC - Page 2
New Exemptions & Penalty Relief for Form 3520 and 3520-A
By Kunal Patel
In early March 2020, the IRS released Rev. Proc. 2020-17 which provides an exemption from the information reporting requirements under IRC § 6048 – specifically, the filing of Forms 3520 and 3520-A. In addition, it provides tax relief for taxpayers…
Court Rejects Reasonable Cause Argument in FBAR Penalty Case
By Kunal Patel
In the recent U.S. v. Ram Agrawal; No. 2:18-cv-00504 the district court rejected the taxpayer’s reasonable cause defense. It granted the government summary judgment in its suit to collect FBAR penalties for taxpayer’s nonwillful failure to file foreign bank account…
IRS Updates Procedures for FBAR Verification Requests
By Kunal Patel
On 11/19, the IRS released a memorandum to issue interim guidance to update the process by which IRS accepts requests for confirmation (verification) that the government received a filed FinCEN Form 114 (formerly TD F 90-22.1), Report of Foreign Bank…