In its recent ruling on United States v. Schwarzbaum, “the Court denied summary judgment for the Government in an FBAR willful penalty collection suit.” Click here for the Order on Motion for Summary Judgment (dated 8/23/19). Click here for Court Listener docket entries with available links to some of the underlying docket entries. According to Townsend, “the court rather cryptically concludes that willfulness is an intent issue that requires a fact trial, whichever standard is used.”
Townsend, Court Rejects Government Summary Judgment Motion in FBAR Willful Penalty Collection Suit (8/28/19)
