District court finds issue of willful FBAR filing failure was inherently factual question.

A district court has denied summary judgment to both IRS and a taxpayer in a case in which IRS imposed the maximum 50% penalty on the taxpayer for willfully failing to file a Report of Foreign Bank and Foreign Accounts (FBAR) with regard to his Swiss bank account. The court concluded that whether the taxpayer willfully failed to submit an accurate FBAR was an inherently factual question and that genuine disputes existed as to what the taxpayer knew about his reporting requirements and when he knew it. Bedrosian v. U.S., (DC PA 4/13/2017) 119 AFTR 2d