Tax Evader Owes 150% Penalty on Swiss Account

A federal jury found an 87-year-old Florida man owes the U.S. government civil penalties amounting to 150 percent of the value of his Swiss bank account, the biggest such penalty by percentage on record, his lawyers said. Carl Zwerner must pay a 50 percent penalty on the annual value of the account in 2004, 2005 and 2006, a total of more than $2 million, for willfully failing to file a U.S. Treasury form called a Report of Foreign Bank and Financial Accounts (FBAR), jurors in Miami ruled yesterday. Prosecutors and the Internal Revenue Service have often used civil FBAR penalties, which sometimes exceed criminal fines, as a weapon in their criminal crackdown on offshore tax evasion. Many of the more than 70 taxpayers charged since 2009 have pleaded guilty, paying an FBAR penalty of 50 percent of the high account balance for only one year.