2023-03-06 Non Willful FBAR Penalty is on a Per Form Basis
This week we look at:
- Deposit and use by sheriff of jail meal money not found to be a mere misunderstanding
- Amounts taxpayer expected to repay with future earnings found not to be loans, taxable upon receipt
- SCOTUS rules non-willful FBAR failure is a per-form not per-account penalty
- CPA fails to provide substantiation for deductions for practice
