Fifth Circuit to Hear IRS Appeal of Jarkesy Block of FBAR Fine

Nov. 14, 2025, 3:32 PM UTC

The government is appealing a lawsuit it lost after a Texas district judge determined it violated the Constitution by levying a tax penalty without a trial.

The US Department of Justice filed a notice of appeal Thursday in the IRS’ case against taxpayer Sharnjeet Sagoo. The case will now go to the US Court of Appeals for the Fifth Circuit, as the government attempts to collect more than $1 million in penalties for failure to file report financial interests in foreign bank accounts, also known as FBAR.

Its case was dismissed in the US District Court for the Northern District ...

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