United States v. Horowitz

The Government has brought this action to collect those penalties, and it moves for summary judgment on its claims. ECF No. 66.1 The Horowitzes have filed a cross-motion for summary judgment, ECF No. 68, arguing that the IRS reversed the 2014 penalties, such that the penalties the Government is trying to collect were not assessed until 2016, at which time they were untimely. They also argue that their failure to disclose was not willful-a point that would reduce the maximum penalties from 50% of the amount in the foreign account at the time of the violation to $ 10,000. Because the Horowitzes…