“Meet Mary Estelle Curran, age 79 and living in Florida. Lest you think Mary is some sophisticated money launderer or drug runner, she is a widow. She inherited a foreign account in a Lichtenstein Foundation from her deceased husband. While the sentencing is still several months away, the IRS penalty for her account is almost $22 million even though the unpaid tax was less than a million dollars. Why so high? The civil penalties for failing to file an FBAR are based on the size of the unreported account. Under current law, the penalty is the greater of $100,000 per year or 50% of the highest account balance for each year the account is unreported.”
formerly http://www.mahanyertl.com/mahanyertl/court-upholds-outrageous-irs-fbar-penalty/3209/
