Legal Opinion

Jarnagin v. United States

United States Court of Federal Claims

Decided November 30, 2017No. 15-1534TPublishedCited by 8 opinions

1Opinion of the Court

Keywords: Tax Refund; Illegal Exaction; IRS; Bank Secrecy Act; Report of Foreign Bank and Financial Accounts; FBAR; Reasonable Cause; Ordinary Business Care and Prudence.

OPINION AND ORDER

KAPLAN, Judge.

In this ease, plaintiffs Larry and Linda Jarnagin, husband and wife, assert that the IRS wrongfully assessed and collected penalties from them for the 2006, 2007, 2008, and 2009 tax years based on their failure to file certain reports regarding their foreign bank account as required by the Bank Secrecy Act. Mr. Jarnagin, a dual U.S.-Canadian citizen, and Mrs. Jarnagin, a U.S. citizen with…

2Cases cited22 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
  4. Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
  5. Bragdon v. AbbottSupreme Court of the United States · 1998

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3Cited by8 opinions

  1. Kimble v. United StatesUnited States Court of Federal Claims · 2018
  2. Landa v. United StatesUnited States Court of Federal Claims · 2021
  3. United States v. AgrawalDistrict Court, E.D. Wisconsin · 2019
  4. United States v. BittnerCourt of Appeals for the Fifth Circuit · 2021
  5. United States v. BittnerDistrict Court, E.D. Texas · 2020

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