U.S. District Court Upholds Willfulness Penalty on Failure to File FBAR

On November 8, 2012, U.S. District Court for the District of Utah, Central Division Judge David Nuffer ruled in favor of the U.S. government that it could collect a civil penalty assessed to Jon McBride for his alleged willful failure to report his interest in four foreign bank accounts during tax years 2000 and 2001 as required under 31 U.S.C. § 5314 and related regulations.  Judge Nuffer held a bench trial on May 21-22, 2012, then took the matter under advisement.[1]