The Isaac Brock Society

Check this out. My question for all is this:

How on the basis of these facts, specifically not knowing about Mr. FBAR in the past, could this be construed to be “willful non-compliance”? Are you saying that the IRS might just make a decision to treat this as willful.? It doesn’t seem to me that in this letter you have:

“now admitted in writing that you are in willful non-compliance with your federal income tax and FBAR filing obligations for the past six years.”

Isn’t the test for willfulness: “The intentional disregard of a known legal duty?” If you don’t know of the duty, how can the disregard be intentional?

This would seem to me to be a very unlikely response from the IRS. If they do respond this way, the outcome is clear:

The word will get out and nobody will ever attempt to bring themselves into compliance again.

Love you hear all your thoughts on this.

Thank you Mr. Mopsick for a very thought provoking post!

Compliance Dilemma For Americans Abroad With No Tax Liability To The United States tinyurl.com/84ukwrj#FATCA#AmericansAbroad

— Mopsick Tax Law, LLP (@MopsickTaxLaw) May 21, 2012

 
I don’t want to belong to any club that will accept people like me as a member — Groucho Marx

 
Over the last day or so, on the Press Release Thread, we have seen perhaps the most sustained and extensive comment so far on the topic of what Isaac Brock Society is and who might speak as representative.

To start with, somewhere in the neighborhood of 350 different persons have posted to Isaac Brock Society by now. Not sorry to lose you probably does not want to count as a “member,” but so far represents an almost empty set. There are 29 persons currently listed as “authors.” Daily traffic runs in a usual range of 4000 to 5000 hits a day, sometimes taking a run up toward a 6000 ceiling. It could be speculated that for every active ongoing commenter there are 100 lurkers. Most days bring forth a handful of first-timers.
Continue reading →