Reply to IRS penalty- Settle or proceed to litigation?

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[quote=Anonymous]I’m the one who guessed it was a 3250. I agree with the pp that you should get a second opinion from someone who is an expert in international tax before deciding what to do. I have a feeling that your attorney does not deal with these forms on a regular basis and that is why the Appeals Officer is taking such a hard line. Similarly, your accountant should have known what to do to report a foreign gift if they handle any type of international issues. Do you have penalties for your FBAR? If your return was extended, your FBAR should have been extended. Definitely get a second opinion. You can have a CPA go with you to Appeals.

To the pp who skipped an FBAR for several years: you may not want to ignore that. You may want to contact one of the accounting firms that specialize in international tax and see if one of the IRS’s streamlined programs can help you get caught up. The IRS has access to foreign bank’s information so it is better to voluntarily disclose than for the IRS to contact you. The threshold for disclosure is 10,000 of your total aggregate balances. So if you have 5 accounts with balances of $3,000 each, you have an FBAR filing requirement.[/quote]

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