201905.11
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IRS Files Complaint to Collect FBAR Interest & Late-Payment Penalty

IRS Files Complaint to Collect FBAR Interest & Late-Payment Penalty (Golding & Golding)

IRS Files Complaint to Collect FBAR Interest & Late-Payment Penalty (Golding & Golding)

IRS Files Complaint to Collect FBAR Interest & Late-Payment Penalty

Like a Predator going in for the kill, the IRS smells blood and has become relentless in collecting Penalties against Teymour Khoubian.

What makes this matter so intense, is that Defendant already paid a $7.7M FBAR Penalty Judgment.

IRS Files Complaint to Collect FBAR Interest & Late-Payment Penalty

Despite the fact that Defendant paid the full amount of the Penalty, the IRS wants to collect more.

Specifically, the IRS is seeking upwards of $86,000 (and counting) in interest, and a whopping $473,000 in a late-payment penalty.

As provided by the Complaint:

On May 25, 2017, the IRS assessed an FBAR penalty of $7,686,003.50 against Teymour Khoubian.


On March 16, 2018, the IRS demanded that Teymour Khoubian pay the FBAR penalty that was assessed against him on May 25, 2017.


Teymour Khoubian did not pay any portion of the FBAR penalty against him within 90 days of the March 16, 2018, demand for payment.


 Under 31 U.S.C. § 3717(e), Teymour Khoubian is liable for a failure-to-pay penalty of 6% per annum for any portion of the FBAR penalty that remained unpaid after 90 days from March 16, 2018. 26.


On November 1, 2018, Teymour Khoubian and his attorney executed a plea agreement in United States v. Teymour Khoubian, case no. 17-cr-452 MWF (C.D. Cal.).


On April 25, 2019, Teymour Khoubian delivered to the United States Attorney’s Office a check in the amount of $7,686.003.50 to be applied to his 2010 FBAR penalty.


As of April 26, 2019, the total outstanding balance of Teymour Khoubian’s liability under 31 U.S.C. § 5321(a)(5) for the calendar year 2010—without consideration of Teymour Khoubian’s April 25, 2019, payment—was computed to be $8,244,028.94 including interest in the amount of $85,493.63 and the late-payment penalty provided for under 31 U.S.C. § 3717(e)(2) in the amount of $472,531.31.


The United States is entitled to judgment against Teymour Khoubian for $558,022.44 as of April 26, 2019, plus all subsequent statutory accruals including interest and penalties, plus costs and expenses, less an adjustment to interest and the failure-to-pay penalty for one day


Why is the IRS So Intense on this Matter?

Presumably, the IRS is going full-throttle due to the criminal nature of the matter (Defendant entered into a plea deal). If Defendant entered into a Plea Deal, that reflects a criminal matter – and not your typical civil FBAR tax matter.

Golding & Golding, A PLC

We have successfully represented clients in more than 1000 streamlined and voluntary disclosure submissions nationwide, and in over 70-different countries.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.

International Tax Lawyers - Golding & Golding, A PLC

International Tax Lawyers - Golding & Golding, A PLC

Golding & Golding: Our international tax lawyers practice exclusively in the area of IRS Offshore & Voluntary Disclosure. We represent clients in 70+ different countries. Managing Partner Sean M. Golding is a Board-Certified Tax Law Specialist Attorney (a designation earned by < 1% of attorneys nationwide.). He leads a full-service offshore disclosure & tax law firm. Sean and his team have represented thousands of clients nationwide & worldwide in all aspects of IRS offshore & voluntary disclosure and compliance during his 20-year career as an Attorney.

Sean holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver. He has also earned the prestigious IRS Enrolled Agent credential. Mr. Golding's articles have been referenced in such publications as the Washington Post, Forbes, Nolo, and various Law Journals nationwide.
International Tax Lawyers - Golding & Golding, A PLC

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