A jury recently upheld a huge IRS penalty accessed to Carl Zwerner for not filing with the Offshore Voluntary Disclosure Program for his offshore account. Since the jury found that Zwerner’s violations were willful, he must pay the maximum penalty of 50% the account balance for the three years that he failed to file. The total amount due in penalties equals more than the balance of the account.
See Charles Rubin, What Does the Zwerner Case Mean to Practitioners?, Ruben on Tax, June 7, 2014.
Special thanks to Brian Cohan (Attorney at Law, Law Offices of Brian J. Cohan, P.C.) for bringing this article to my attention.
