Jack Townsend (Federal Tax Crimes Blog): FBAR Civil Willful Penalty Sustained Against Long Time Accountant and Tax Preparer Who Claimed He Did Not Have Time to Read the Schedule B Instructions (June 4, 2021)

Jack Townsend has made available for download his article, “FBAR Civil Willful Penalty Sustained Against Long Time Accountant and Tax Preparer Who Claimed He Did Not Have Time to Read the Schedule B Instructions”, published on his Federal Tax Crimes blog. The abstract is as follows:

In United States v. Kronowitz (S.D. Fla. No. 19-cv-62648 Findings of Fact and Conclusions of Law dated 6/3/21), CL here, the Court sustained the Government’s assertion of the FBAR civil willful penalty.  The facts were bad for Kronowitz in trying to avoid the penalty.  He was an accountant and regular tax return preparer over many years.  He claimed inter alia (slip op. 11):

He admitted to seeing hundreds of Schedule Bs, and being familiar with the purpose of Schedule B and its requirements, but testified that he probably did not read the instructions because he was more concerned with providing for his family and taking care of his clients. Indeed, he testified that “my purpose in life at the time was to get clients, bill them, and collect the money, not spending the whole year reading[.]”

Well, he lost.

Click here to view Jack Townsend’s summary of United States v. Kronowitz (S.D. Fla. No. 19-cv-62648 Findings of Fact and Conclusions of Law dated 6/3/21)

Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.