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11th Circ. Wary Of IRS Procedure In FBAR Penalty Appeal

By Kelcey Caulder ( October 7, 2025, 10:35 PM EDT) -- An Eleventh Circuit panel Tuesday appeared concerned about IRS procedures that could keep a man from recouping $419,000 he paid to resolve his failure to disclose funds held in foreign bank accounts as he appeals a district court determination that he actually owes $2.2 million....

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