Unreasonable about FBAR reasonable cause?

Unreasonable about FBAR reasonable cause?



We've seen IRS examiners focus solely on "reliance upon a tax professional." Even though this is not what the IRM states. Also, for a future topic, I am looking at how the Treasury regulations requiring an FBAR to be filed have nothing to do with the claimed authorizing statute. That is , 31 U.S. Code § 5315 - Reports on foreign currency transactions, is about reporting the import and export of currency, not reporting foreign bank accounts. Not that this argument matters much, it's more of an interesting point that will be ignored. But still, a terrific argument.