Jay R. Nanavati Quoted In "FBAR Decision Shows IRS Winning On Willfulness, Practitioner Says", Tax Notes

Even though the taxpayer in the case was found not to have willfully failed to file a foreign bank account report, a district court opinion applying a lower willfulness standard for heightened FBAR penalties shows that the IRS is winning the war on the issue, a practitioner said September 22.

"The IRS may have lost the battle for a single willful FBAR penalty in Bedrosian, but it won the war by convincing the court to adopt the lower civil willfulness standard in FBAR cases," said Jay R. Nanavati of Kostelanetz & Fink LLP.

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