Zhanna Ziering quoted in Tax Notes on IRS’s Abuse of Discretion Over Willful FBAR Penalties
Another district court has held that although a taxpayer willfully failed to file foreign bank account reports, the IRS acted arbitrarily in setting the penalty amount, and it has remanded the case for recalculation. Zhanna Ziering quoted in Tax Notes article titled IRS Abused Discretion Over Willful FBAR Penalties, Court Holds.
