Gorsuch: $2.1 million IRS civil penalty for unreported Swiss bank account merits SCOTUS review

Source: ABA Journal

“Justice Neil Gorsuch argued Monday that the U.S. Supreme Court should have agreed to hear the case of a woman who argued that the Internal Revenue Service violated the excessive fines clause when it required her to pay a $2.1 million civil penalty for failing to report a Swiss bank account. The woman, Monica Toth, had $4.2 million in her account when the IRS imposed a civil penalty of half the balance and assessed another $1 million in late fees and interest, wrote Gorsuch in his Jan. 23 dissent to the cert denial. … Toth had received the money in the Swiss bank account as a gift from her father, who had ‘a successful business career in Buenos Aires’ after escaping from Nazi Germany …. For several years, she failed to report the account as required by law. Toth said she didn’t know about the requirement, and when she learned of it, she completed the disclosure forms.” (01/24/23)