“Consider 79 year-old Mary Estelle Curran of Palm Beach who inherited Swiss and Liechtenstein accounts when her husband died in 2000. She failed to report them and the IRS lost out on approximately $667,716 in taxes. That’s a lot of money to be sure, but the size of her penalty was, well, enormous: 50% of the highest balance: $21,666,929. And that’s not all. She was facing serious jail time too. And it seemed doubly unfair that she was unsophisticated and had tried to come forward to the IRS long before. Fortunately, though, U.S. District Judge Kenneth Ryskamp eased up, even suggesting that the government could probably use a little more discretion.”
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