The Pomerantz willful FBAR case: Taxpayer wins! (for now)

The Pomerantz willful FBAR case: Taxpayer wins! (for now)

http://ift.tt/2rwh6HE The government wanted to start collecting willful penalties against dual US/Canadian citizen Jeffrey P. Pomerantz. It filed a complaint in US federal court to do so. Things did not go so well for the government. The IRS and the US government faced significant push back from Judge James L. Robart of the Western District of Washington Court. The court the complaint faulty as it failed to allege facts to support a willful FBAR penalty on an account with CBIC. And while the complaint barely alleged enough facts to support a willful penalty against a Swiss bank account held by Mr. Pomerantz, the FBAR penalties were jumbled together and unable to be separated. Therefore the entire action failed. Mr. Pomerantz represented himself pro se. This means he represented himself Although tit appears as if he has some help from a lawyer or two who knew their way around FBAR penalties. http://ift.tt/1RfwK1f Parent & Parent LLP 60 EAST 42ND STREET, SUITE 4600 New York, NY 10165 (212) 256-1335 The taxpayer won. More importantly the court held firm that the government has the burden of proof to assess willful FBAR penalties. The government will refile and we will monitor. https://youtu.be/ZXOH0v85xCE IRS Medic