FBAR penalties: Legal implications after death

A district court ruled that penalties for failing to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, (FBAR), accrue on the due date of the form and that an individual’s death does not extinguish these penalties. The court also determined that these penalties are not nullified by the individual's death and are not considered excessive under the Eighth Amendment. Additionally, the court found that the government was not restricted by the statute of limitations in assessing