No leg to stand on

U.S. citizens must generally file a Report of Foreign Bank and Financial Accounts (FBAR) if they have an account in a foreign country and meet certain requirements. Failure to file an FBAR can result in penalties as high as the greater of $100,000 or 50% of the unreported balance if the failure was willful. When one taxpayer was hit with an FBAR penalty of $1.36 million, he demanded the IRS provide “clear and convincing evidence” that the failure was willful. The Fifth Circuit ruled he lacked standing to enforce his demand. (3/13/16, 2017-532)