On November 30, 2021, the United States Court of Appeals for the Fifth Circuit issued its viewpoint in U.S. v. Bittner. Contrary to decisions of other federal courts, the Fifth Circuit concluded that it was suitable for the IRS to impose non-willful FBAR penalties against the taxpayer, Mr. Bittner, on a per-account, alternatively than a per-yr, basis. The Fifth Circuit even further concluded that Mr. Bittner had failed to set up affordable induce for abatement of the penalties….
By: Freeman Legislation
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