Does an Amended Tax Return Extend the Statute of Limitations?
Kimble v. United States, Court of Claims No. 17-421 – FBAR Willfulness Penalty Case
Recent Tax Opinion Highlight: The opinion of United States Court of Appeals for the 3rd Circuit in Arthur Bedrosian v. United States, a recent FBAR willfulness penalty case.
Posted 12/24/2018, By Daniel W. Layton: The 3rd circuit in Bedrosian v. United States has issued an opinion which appears to be saying that full-pay refund jurisdiction which ordinarily applies in a Title 26 tax case applies in FBAR penalty cases. On the other hand, the Third Circuit is taking the position that the standard of willfulness is lower than a Title 26 tax case. Is this consistent? Why doesn’t the reasoning applicable for jurisdiction purposes also applicable for determining how the IRS is expected to apply the penalty itself?…. Click here for the full opinion in HTML and PDF.