This post appeared on the RenounceUScitizenship blog. It is a continuation of an earlier post on FBAR and the 8th amendment. Mr. Zwerner may well be on his way to being discussed in a law school constitutional law class.
— U.S. Citizen Abroad (@USCitizenAbroad) September 26, 2013
Those interested in the saga of Carl Zwerner – the 86 year old Florida resident – who was assessed multiple year willful FBAR penalties, AFTER having made a traditional voluntary disclosure at a time before OVDP was available – need to read this post by Charles Rettig. Mr. Rettig does a nice job of laying out the chronology. Leaving aside the specifics (I encourage you to read his post) he summarizes the main point as follows: