In United States v. Rum, No. 19-14464 (11th Cir. April 23, 2021), the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision in granting summary judgment in favor of the government, enforcing the IRS assessment of a penalty for a willful FBAR violation. The individual placed money in a foreign bank account for concealment purposes. The taxpayer raised several arguments including that the district court applied an incorrect standard of willfulness.
Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.