Federal Tax Crimes: Another Failed Judicial Contest of the FBAR Willful Penalty (March 23, 2021)

Jack Townsend, in his Federal Tax Crimes Blog, discusses the failed attempt to overturn the FBAR civil penalty in Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21).

In Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21), TN here, in an appeal from an adverse holding in a refund suit, the Court sustained the willful FBAR civil penalty.  Unfortunately for Kimble, neither the facts nor the law was helpful.

The Court almost summarily dispatched Kindle’s main arguments about the CFC’s holding sustaining the penalty.

To download the opinion, click here: Kimble v. United States, ___ F.3d ___ (Fed. Cir. 3/22/21)

To view the full article, click here: “Another Failed Judicial Contest of the FBAR Willful Penalty”