IRS Wins Default Judgment in $18M FBAR Penalty Case Recently, a California U.S. District Court entered default judgment in favor of the Government in an FBAR penalty suit in the case of United States v. Masud Sarshar, Case No.: 2:18-cv-7751. Summary of the FBAR suit From the Government’s motion: Masud Sarshar is a United States citizen who, for tax years 2006 through 2012, maintained accounts subject to the reporting requirements of 31 U.S.C. § 5314, as implemented under 31 C.F.R. §§ 1010.350(a) and 1010.306(c). These provisions require that each United States person having a financial interest in, or signature or other authority over a financial account in a foreign country report that interest annually on a form called a Report of Foreign Bank and Financial Accounts, which is also referred to as an FBAR. As set forth in 31 U.S.C. § 5321(a)(5)(C)(i), for willful violations of the FBAR-reporting requirements, Congress authorized a maximum penalty…
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