Seriously? IRS Assesses US$5.1 Million FBAR Penalty for “Signature Authority”
I have been keeping readers up to date with the current controversy surrounding imposition of an FBAR penalty for “willful” violations – is it limited to a $100,000 cap or can the penalty, if greater, be assessed at 50% of the value of the unreported account? More detailed background on this issue is available at my blog post here. We have seen that the Internal Revenue Service (IRS) has been hitting the FBAR penalty jackpot recently. The cases are gaining momentum to support the imposition of “willful” FBAR penalties well above the $100,000 cap. The 50% penalty looks like it’s a goldmine “go” for the IRS, and the agency appears to be consistently winning.
With this background, the next question: How aggressive can the IRS get when it comes to assessing “willful” FBAR penalties? Today’s post involving the case of Jonathan Zuhovitzky will present the perfect example!