Prior to 2023 and 2024, taxpayers faced significant challenges in contesting penalties for failing to report foreign accounts via the Foreign Bank and Financial Accounts (FBAR). However, recent court decisions signal a shift in the legal landscape. Despite this change, FBAR litigation remains far from straightforward. The cases discussed below share a common theme: They explore various approaches to challenging assessed FBAR penalties. Each case, though, has a different approach: focusing on
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