Jack Townsend, in his Federal Tax Crimes Blog, discusses United States v. Collins, 2021 U.S. Dist. LEXIS 23260 (W.D. Penn. 2/8/21).
The Court’s reasoning for its principal holding that the de novo review standard applies rather than the APA abuse of discretion standard echoes the holding that, since Tax Court deficiency review is de novo, abuse of discretion will not apply.
To see the full article, click here: “Court Holds Taxpayer Liable for FBAR Civil Willful Penalty”
To download the full opinion, click here: United States v. Collins, 2021 U.S. Dist. LEXIS 23260 (W.D. Penn. 2/8/21)