In a recent decision, the failure of the IRS to follow its internal procedure as set forth in its Internal Revenue Manual for IRS revenue agents and/or revenue officers, does not negate the assessment of FBAR (Report of Foreign Bank and Financial Accounts) penalties. See Mitchell v. United States, 124 AFTR 2d 2019-5082 (Ct. Fed. Cl. 7/24/2019). According to the Federal Court of Claims, IRS Letter 3709 containing an IRS manager’s signature indicates that the FBAR penalties were properly assessed. Consequently, the plaintiff was not entitled to Form 400-1.1, an IRS internal work paper.
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*This post was originally published on August 5, 2019
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