A taxpayer facing a nearly $1 million penalty for failing to report a foreign bank account has brought his dispute to the US Supreme Court.
Arthur Bedrosian is petitioning the high court to review his July loss at the US Court of Appeals for the Third Circuit, arguing that the appeals court erred in determining that he willfully failed to submit a report of Foreign Bank and Financial Accounts on his Swiss bank account.
Most taxpayer may think that they won't face the penalty if the required pror years' FBAR is missed. In fact, they could be assessed the penalty by IRS.
Willful FBAR penalties are capped at 50% of the assets of the foreign bank account or $100,000, based on whichever is the larger amount. Non-willful reporting penalties are capped at $10,000.
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