The U.S. Supreme Court Agreed with Precedent Set by Taylor Nelson Amitrano LLP and Determined The Maximum Non-Willful Penalty For A Late-Filed FBAR Is $10,000
SANTA ANA, Calif., March 1, 2023 /PRNewswire-PRWeb/ -- Taylor Nelson Amitrano LLP, a prominent tax controversy firm located in Santa Ana, CA, is pleased to announce that the U.S. Supreme Court, in the case of Bittner v. U.S., resolved a circuit split and agreed with the precedent set by Taylor Nelson Amitrano LLP, in its 9th Circuit Court victory in the matter of U.S. v. Boyd. In doing so the U.S. Supreme Court made clear that the maximum penalty for failing to timely file an FBAR is $10,000 per year if the failure to file is not willful.
- The decision resolves a circuit split and follows the precedent set by the firm's victory in the matter of U.S. v. Boyd in the 9th Circuit Court.
- In doing so the U.S. Supreme Court made clear that the maximum penalty for failing to timely file an FBAR is $10,000 per year if the failure to file is not willful.
- Because of the Circuit split between the 5th Circuit and 9th Circuit Court of Appeals, Bittner appealed to the U.S. Supreme Court who granted certiorari.
- In ruling in favor of Bittner, the U.S. Supreme Court referenced the 9th Circuit Court of Appeal decision in Boyd.