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Case: In FBAR Collections Case Where Taxpayer Living Abroad Could Not Be Located, Alternate Service Via Prior U.S.-Based Attorneys Allowed (S.D.N.Y.)

Jan. 25, 2023, 5:00 AM

In FBAR penalties collection case, where Taxpayer (U.S. citizen living abroad) could not be located in Europe after the government was unsuccessful at serving Taxpayer (through the Hague Convention and other methods), the government’s motion for alternate service via Taxpayer’s prior attorneys in the United States was granted, a district court held. The attorneys (1) represented Taxpayer in 2018-19 in underlying FBAR penalty case, (2) presumably had ongoing communications with Taxpayer via email for that case, (3) didn’t indicate that they recently tried to reach him without success, and (4) have a duty to attempt service as officers of the ...