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FBAR examination? Find out how to avoid having the IRS succeed in imposing the larger penalty for willful behavior.
First and foremost, an FBAR battle is being waged in federal courts across the country where taxpayers have been seeking to avoid the imposition of the maximum FBAR willfulness civil penalty. Faced with an adverse result during an IRS civil examination or administrative appeal, taxpayers have turned to litigating the civil penalties in federal court […]