WSJ: Jury Imposes $2.2m Penalty on $1.5m Account in Tax Case

Wall Street Journal Tax Report:  The IRS Wins a Big Offshore Case, by Laura Saunders:

Offshore account holders take note: In what experts call a big win for the IRS, a Miami jury has found that a millionaire could owe penalties of $2.2 million on a secret Swiss bank account that held about $1.5 million.

Experts say the decision in U.S.A. v. Zwerner, a civil case that concluded in May, could encourage the IRS to assess outsize fines in similar cases. ...

Mr. Zwerner's case is the first to become public in which offshore-account penalties exceeded the account balance, experts say. Under a 2004 law, taxpayers can owe up to 50% of an offshore account's highest balance for each year they "willfully" fail to file an annual Foreign Bank Account Report—or Fbar—disclosing accounts totaling $10,000 or more.