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Josh Ungerman was quoted in an article by Andrew Velarde in Tax Notes on March 1, 2023

Firm Partner, Josh Ungerman was quoted in a recent Tax Notes article written by Andrew Velarde, “Supreme Court Hands Huge Victory to Non-Willful FBAR Violators” regarding the Supreme Court decision in the case Bittner v. United States, in which they found that non-willful foreign bank account reporting penalties apply per form, and not per account.

According to Mr. Ungerman, the decision is the culmination of a “David versus Goliath scenario” and serves as a prime example of an individual taxpayer's ability to prevail against the IRS over a legal interpretation. “The Supreme Court wisely followed the [Boyd] circuit, and now the law of the land is as it should be,” Ungerman said. “The Bittner opinion demonstrates that taxpayers should not be afraid to challenge the IRS interpretation of a particular authority.”