Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.
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Monday, May 4, 2015
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.
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