US v. Toth

  1. April 29, 2022

    1st Circ. Affirms No Cap On Woman's $3.1M FBAR Bill

    The IRS can collect $3.1 million for a woman's failure to disclose her Swiss account after the First Circuit joined other appeals courts Friday in rejecting assertions that a 1987 regulation is active and caps her penalty at $100,000.

  2. October 26, 2021

    1st Circ. Says Appeal Of $3M Tax Fine Faces Obstacles

    A First Circuit panel suggested Tuesday that it may not be able to overturn a $3.2 million judgment against a Massachusetts woman for failing to report a Swiss bank account given the appeals court's past decision upholding a similarly steep financial penalty.

  3. August 26, 2021

    FBAR Error Doesn't Warrant $3.2M Penalty, 1st Circ. Told

    The First Circuit should overturn a $3.2 million penalty against a woman accused of hiding her Swiss bank account because the government misleadingly portrayed her as culpable and the fine is excessive, she told the court. 

  4. July 08, 2021

    Gov't Urges 1st Circ. To Let $3.2M FBAR Judgment Stand

    A $3.2 million judgment against a taxpayer for willfully failing to report her Swiss bank account should stand because of her reckless disregard for reporting requirements, the U.S. has told the First Circuit.