Certain taxpayers who are citizens of foreign countries also have green cards granting them resident status in the United States. Some argue the laws regarding their obligation to file FBARs are unconstitutionally vague.
Tag archives: Failure-to-file
The Government Has Focused a Considerable Amount of Energy To Prosecute Taxpayers Who Failed to File FBAR Reports and Accurately Account For Taxes. The Government has used the Required Records Doctrine to compel taxpayers to produce foreign bank account records.
Taxpayer was convicted pursuant to 7203 for failing to file several tax returns. Taxpayer appeal based upon the alleged misconduct of the prosecutor. The Court affirmed based upon "harmless error".
Federal Sentencing Guidelines Treat Felony and Misdemeanor Tax Violations the Same. The Result Can Lead to Misdemeanor Sentences Being Ordered Served Consecutively.
Defendant Charged With Tax Evasion Waived a Valid Venue Argument by Failing to Make a Timely Motion.