Man Can’t Get FBAR Penalties Overturned, 11th Circ. Rules

On Apr 25, 2021

Law360 (April 23, 2021, 7:27 PM EDT) — A naturalized citizen must face tax penalties for his failure to report foreign bank accounts to the Internal Revenue Service because the government proved he willfully attempted to hide his income overseas, the Eleventh Circuit said Friday.

A three-judge panel affirmed that a Florida federal court correctly held Said Rum liable for the maximum penalty for his failure to file Reports of Foreign Bank and Financial Accounts, according to the per curiam opinion. Rum failed to prove that the penalty, which the IRS set at 50% of the funds in his unreported account, was arbitrary and capricious, according to the opinion….

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Man Can’t Get FBAR Penalties Overturned, 11th Circ. Rules

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