On Procedural Due Process in FBAR Pre-Assessment Procedures (5/4/15)

I recently wrote on the Moore case involving a challenge to a mutli-year FBAR nonwillful penalty.  See Court Approves FBAR NonWillful Penalty Merits But Wants Further Development of APA Issues (Federal Tax Crimes Blog 4/3/15), here.  One of the issues I noted but did not discuss was the procedural due process issue.  Les Book has a great discussion of this issue in Procedural Due Process and FBAR (Procedurally Taxing 5/4/05), here.