Another Taxpayer Denies That Their Failure To File an FBAR Was Willful

In U.S. v. Vettel, case number 4:21-cv-03099, in the U.S. District Court for the District of Nebraska, a Nebraska resident denied the U.S. government's claims that his failure to report holdings in a Swiss bank account that received money from a sham corporation in Belize constituted willful failure to file, according to filing in Nebraska federal court.

David L. Vettel's attorney admitted his client did not file a report of foreign bank and financial accounts for 2006 through 2011, but he should not be liable for almost $637,000 in penalties, interest and fees resulting from the maximum penalty being assessed, the attorney told the court.

Vettel also denied the allegations that he set up a corporation in Belize for the sole purpose of holding his account at the Swiss bank BSI SA, which U.S. attorneys in their complaint claim received deposits totaling more than $1.6 million from 2006 through 2010.

During the years in question, Vettel employed a certified public accountant to prepare his federal income tax returns but didn't disclose the bank account to the CPA, nor any of the money deposited into the account on his federal returns for those years, according to the government.  LOTS OF LUCK with this defense!!!

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