To what extent does the IRS have to impose penalties for non-tax reporting?  

The question being posed to the US Supreme Court in Bittner V. U.S. is do they have the right to impose severel penalties to a taxpayer due to an oversight?

These are the questions that are being posed to the Supreme Court.

At the center of the case is a taxpayer who has several foreign bank accounts and recently became a citizen of the United States is responsible for the fines that are imposed by the IRS that amount to over 2.7 million dollars.  The IRS has the auithority to assess up to $10,000 per violation and civil penalties on top of that.   But through the magic of a compounding in the IRS favor that translates into 272 violations, over 5 years.  

Hopefully the Supreme Court can apply some common sense to this case.

 





dougzandstra

Doug Zandstra CPA CFE EA

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