Miami Jury Finds 87-Year-old Man Willfully Failed to Report Swiss Account

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Monday, September 1, 2014
Bruce Zagaris
On May 28, 2013, a jury in Miami, Florida found Carl R. Zwerner responsible for civil penalties for willfully failing to file required Reports of Foreign Bank and Financial Accounts (FBARs) for tax years 2004 through 2006 with respect to a secret Swiss bank account he controlled.  The evidence the government introduced at trial showed the balance of the bank account during each of the years at issue was in excess of $1.4 million.  The jury found Zwerner should be liable for penalties for 2004 through 2006.  Zwerner faces a maximum 50 percent penalty of the balance in his unreported bank account for each of the three years.  The jury found that Zwerner’s failure to report the account was not willful for 2007.  The court will determine the final amount of the judgment after further proceedings in June 2014.[1]