Alison Kehner Publishes Article Analyzing Two Key Decisions in Civil FBAR Penalty Litigation

Alison Kehner’s article, “Bank Secrecy Act and IRS Civil Penalties: The Third Circuit Addresses FBAR Willfulness,” was recently published in the December issue of On Appeal, the official newsletter of the Bar Association for the Third Federal Circuit. The article analyzes United States v. Collins, 36 F.4th 487 (3d Cir. 2022) and Bedrosian v. United States, 42 F.4th 174 (3d Cir. 2022), which affirmed large civil penalty assessments levied against taxpayers who failed to disclose, or filed incomplete disclosures of, their interests in foreign bank accounts in violation of the Bank Secrecy Act. Alison is currently serving a three-year term on the Third Circuit Lawyers’ Advisory Council and is a regular contributor to On Appeal.