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