Posted by: Taxlitigator | September 26, 2013

Zwerner Answers DoJ Efforts to Collect Multiple 50 Percent Civil FBAR Penalties


Responses

  1. “The jury trial in Zwerner began on May 19, 2014 in the Federal District Court for the Southern District of Florida. The government assessed penalties against Mr. Zwerner under 31 U.S.C. § 5321(a)(5) in the amount of 50% of the high balance of his account at the time of the violations for each year, as follows: (a) 2004 – $723,762, assessed on June 21, 2011; (b) 2005 – $745,209, assessed on August 10, 2011; (c) 2006 – $772,838, assessed on August 10, 2011; and (d) 2007 – $845,527 assessed on August 10, 2011.

    It is being reported that the jury returned a verdict today, May 28, 2014, finding Mr. Zwerner liable for an FBAR penalty equivalent to 50% of the high balance in his foreign financial account for 3 of the 4 years previously assessed by the government.

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