tag:blogger.com,1999:blog-1519969502186924526.post7923576873373249383..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Zwerner Rises to Defense Against Multiple FBAR Penalties (9/28/13)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger8125tag:blogger.com,1999:blog-1519969502186924526.post-59414132330528992582013-10-01T14:47:50.152-05:002013-10-01T14:47:50.152-05:00Yes you would think so but I have my doubts now.
I...Yes you would think so but I have my doubts now.<br />Imo. I think mediation will already provide a settlement and it will be sealed which means we will not know any details. I still think that Zwerners chances are > 50% to win a jury trial and have his multiple FBAR penalties reduced significantly.GlobalCapitalismnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-5776388926858819362013-10-01T14:46:59.811-05:002013-10-01T14:46:59.811-05:00Sorry, I had initially prepared a summary of Chuck...Sorry, I had initially prepared a summary of Chuck Rettig's article on the subject but then decided to pull the answer and essentially do my own blog rather than just respond to Chuck's article. So, I have taken out that reference, but I do cite Chuck's article at the end of the blog.<br /><br />Chuck's article is here: http://www.forbes.com/sites/irswatch/2013/09/26/zwerner-answers-doj-effortsto-collect-multiple-50-percent-civil-fbar-penalties/<br /><br /><br /><br />Jack TownsendJack Townsendhttp://www.tjtaxlaw.com/noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-91576987621218744042013-10-01T14:37:55.567-05:002013-10-01T14:37:55.567-05:00My only concern is that I believe that DOJ Tax wou...My only concern is that I believe that DOJ Tax would have picked a carefully selected case in which they thought all the facts, considered in context, might justify the 4 FBAR willful penalties. So, I think there are still some facts and considerations that we don't know. Not that I think the penalty will be affirmed; just that DOJ would not pick an obvious loser in its first case to assert multiple FBAR penalties and that conceptually on a static amount would mean an FBAR penalty of 200%.Jack Townsendhttp://www.tjtaxlaw.com/noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-27131030052221182692013-10-01T13:12:15.925-05:002013-10-01T13:12:15.925-05:00On August 9, 2013 the judge ordered mediation. Th...On August 9, 2013 the judge ordered mediation. The mediation conference is to take place with Samuel C. Ullman on Jan. 28, 2014 in Ft. Lauderdale, Fla. and the parties are to submit a report within seven days of the mediation conference. (I got this info from the public court record and have no inside knowledge of the case.) I am disappointed that there likely won't be new developments soon. Also, Mr. Ullman specializes in tax matters. In spite of the IRS being involved, FBAR compliance is a banking law, not a tax code law.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-89666199688726001162013-10-01T12:48:27.482-05:002013-10-01T12:48:27.482-05:00Jack, you said "I focus here on Chuck's d...Jack, you said "I focus here on Chuck's discussion of Zwerner's answer." I don't know who Chuck is or where his discussion might be found.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-35397503626331212382013-10-01T06:33:30.856-05:002013-10-01T06:33:30.856-05:00good question GC and I would agree with you on tha...good question GC and I would agree with you on that he has a few good facts on his side. I think he would get his monster FBAR penalty reduced significantly .Brutus Maximusnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-40505301772304625962013-09-30T00:46:32.548-05:002013-09-30T00:46:32.548-05:00Good job with the post!! thank you for the informa...Good job with the post!! thank you for the informative share!<br /><br />http://www.allenbarron.comPeterKenneth24noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-12669938398865332072013-09-29T08:52:34.735-05:002013-09-29T08:52:34.735-05:00Jack YOU still suck but ZWERNER - YOU rock !Jack YOU still suck but ZWERNER - YOU rock !SeniorResearchernoreply@blogger.com