Case: Taxpayers Willfully Failed to File FBARs (D. Or.)

There are genuine issues of material fact regarding whether Taxpayers willfully failed to disclose their Iranian bank accounts in 2011 in FBAR penalty case under 31 U.S.C. § 5321(a)(5)(A); however, Taxpayers willfully failed, as a matter of law, to disclose their Iranian back accounts in subsequent years and their Canadian bank accounts for all three years at issue, a district court held, granting in part and denying in part the government’s motion for partial summary judgment. [Malekzadeh v. United States, No. 3:20-cv-1887-IM (D. Or. Jan. 24, 2023)]

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