Appellate Court Affirms Heavy Willfulness Penalties in FBAR Case

                On September 4, 2026, the United States (U.S.) Court of Appeals for the Fourth Circuit unanimously affirmed a district court summary judgment order that authorizes the assessment by the Internal Revenue Service of $2,915,633 in civil penalties for a taxpayer’s willfully failing to report his interest in multiple foreign bank accounts over several years.  The appellate court rejected the taxpayer Richard Rund’s defense that the penalties violated the Excessive Fines Clause of the Eighth Amendment to the U.S. Constitution.