The government has won four FBAR penalty cases in a row against taxpayers, asserting maximum FBAR penalties, which are reserved for taxpayers who commit "willful" violations. That the government achieved this series of victories is discouraging by itself but the standards that the courts set can be downright dispiriting to taxpayers with ongoing FBAR problems.

This two-part report will give taxpayers a closer look at these four cases and help provide a clear understanding of the relevant law and current standards for "willfulness".