IRS Defends Authority to Assess Penalties Over Foreign Reporting

A couple’s $2.14 million lawsuit over penalties for not reporting foreign bank assets should fail because the IRS correctly calculated their liabilities and had the authority to assess the penalties at issue, the agency told a federal court.

Robert Junke and Toni Hill failed to state a claim for which relief can be granted because IRC Section 6677 empowers the IRS to assess penalties against the couple for not filing information with respect to foreign trusts, the agency told the US District Court for the Western District of Pennsylvania on Tuesday. Junke and Hill say the assessments should be refunded ...