tag:blogger.com,1999:blog-1519969502186924526.post114322158323654996..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: ABA Tax Lawyer Publication Comment on FBAR Willful Penalty (2/16/15)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger1125tag:blogger.com,1999:blog-1519969502186924526.post-3240536777242704962015-02-16T12:24:18.351-06:002015-02-16T12:24:18.351-06:00well written article although not sure it really a...well written article although not sure it really advances the argument or tells the tax public something "they don't already know". Reality is, Mcbride and Williams have provided the Service with a fantastic enforcement tool, one that is more or less only hindered by prosecutorial discretion. So unless Congress changes the law (unlikely) or the Service loses a case at appellate level and the SC weighs in, the pseudo strict liability currently imposed by these two cases is pretty much the lay of the land.gottaloveUStax1noreply@blogger.com