United States v. Keago

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that failure to read this question does not change that a taxpayer is on inquiry no- tice
• holding that “willful blindness” in certain circumstances “may be inferred”
• observing that not reading line 7a and not paying attention to tax returns “constitute^] willful blindness to the FBAR requirement” and that line 7a “put [the taxpayer] on inquiry notice of the FBAR requirement”
• using de novo review, noting that § 5321 contained no guidance on the legal standards to be employed in the action for collection it authorized, and comparing section to review of Tax Court and other agency decisions
• “Whether a person has willfully failed to comply with a tax reporting requirement is a question of fact.”
• tax payer’s signature is prima facie evidence that he knew the contents of the return and line 7a’s instruction for exceptions and filing requirements for FBAR put taxpayer on inquiry notice of the FBAR requirement

Source: CourtListener parenthetical corpus (CC0).