The IRS has just issued new FAQs related to the Foreign Bank Account Reports (FBAR). There are 21 new offshore financial account penalty as part of the FBAR prior post. If the taxpayer disagrees with the imposition of the penalties then the taxpayer may go to the IRS Appeals Division.
It is unfortunate that the IRS has chosen to take this draconian stance with respect to the tax litigation attorneys are currently advising clients with tax attorneys at Brager Tax Law Group, A P.C.