Wednesday, August 16, 2023

Yes Yet Another FBAR Penalty Being Dropped Based Upon Bittner

According to Law360, a New York federal judge approved an $80,000 settlement in a $330,000 dispute between a woman and the federal government over improperly reported overseas accounts. The case is U.S. v. Bouskila, case number 2:21-cv-04243, in the U.S. District Court for the Eastern District of New York.

Cecile Bouskila will pay the $80,000 settlement as well as 1% annually accruing interest from the date of the amount-due notice, a 6% annually accruing late-payment penalty from 90 days after that notice and other post-judgment interest, according to the order

The Internal Revenue Service Had Previously Assessed
$330,000 In Penalties For Bouskila's Failure To Timely
File Reports Of Foreign Bank And Financial Accounts,
Or FBARs, From 2004 Through 2011.

In March, the U.S. Supreme Court ruled in a separate case that the $10,000 maximum penalty dictated by the Bank Secrecy Act is applicable per annual form, rather than per account. Bouskila had previously argued that sentiment, claiming that she was liable for a maximum penalty of $80,000.

Have an FBAR Penalty Problem?  
Never Stop Arguing
Legal Basis for Abatement!

 Contact the Tax Lawyers at 
Marini& Associates, P.A. 
for a FREE Tax Consultation at: or 
Toll Free at 888-8TaxAid (888) 882-9243

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