§5321

We hold that it does not.

§ 5321(a)(5)(A). The Secretary has delegated to FinCEN the authority to enforce the provisions and impose civil penalties for violations of 31 U.S.C. § 5314. See 31 C.F.R. § 1010.810(d) (2023). FinCEN subsequently redelegated this authority to the IRS. See 31 C.F.R. § 1010.810(g); see also Delegation Order 25-13, Internal Revenue Manual 1.2.2.15.13 (Mar. 8, 2022). Notwithstanding this redelegation, Title 31 and its accompanying regulations govern how FBAR penalties are assessed and collected. Ti

§ 5321(a)(5)(C) for willfully failing to timely declare his foreign bank accounts for tax years 2006, 2007, 2008, 2009, 2010, and 2011.4 IV. Request for Relief from Joint and Several Liability While negotiations in the deficiency case were ongoing, petitioner, Mr. Vettel, and their representatives internally discussed the possibility of pursuing in

§ 5321 for FBAR Violations; • An Offshore Entity Statement; • An Offshore Voluntary Disclosure Letter with Required Attachments; and • Copies of Forms 2848, Power of Attorney and Declaration of Representative, for Ronald Schlapfer and Linda Schlapfer. With this submission, Mr. Schlapfer attempted to comply with applicable U.S. tax laws. For 2004, 2

Section 7623(b)(5)(B) provides that for a whistleblowerto qualify for the mandatorywhistleblower award, "the tax, penalties, interest, additions to tax, and additional amounts in dispute [must] exceed $2,000,000." In Whistleblower22176-13W, the whistleblowerprovided information to the Government that resulted in the collection ofa sm

Section 7623(b)(5)(B) provides that for a whistleblowerto qualify for the mandatorywhistleblower award, "the tax, penalties, interest, additions to tax, and additional amounts in dispute [must] exceed $2,000,000." In Whistleblower22176-13W, the whistleblowerprovided information to the Government that resulted in the collection ofa sm

5321(a) (2006). Taxpayer 1 also agreed to pay the IRS a relatively small amount of restitution, reflecting unpaid Federal income tax due on income earned from the Swiss bank accounts. Petitioner claimed entitlementto an award based upon the aggregate amountpaid by Taxpayer 1, given petitioner's alleged involvement in the Swiss banker's arrest,

section 5321, for failure to file foreign bank account reports (FBARs) disclosing Swiss bank accounts . The petition ends with a prayer "that any tax deficiency, FBAR penalty, and/or interest be abated . " Discussion The Tax Court is a court of limited jurisdiction . We may therefore exercise jurisdiction only to the extent expressly provided by st

section 5321, for failure to file foreign bank account reports (FBARs) disclosing Swiss bank accounts. The petition ends with a prayer “that any tax deficiency, fbar penalty, and/or interest be abated.” Discussion The Tax Court is a court of limited jurisdiction. We may therefore exercise jurisdiction only to the extent expressly provided by statut