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FBAR Willful Penalty: What is the Definition of Willfulness?
https://www.goldinglawyers.com/fbar-willful-violations-how-do-courts-define-fbar-willfulness/
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FBAR Willful Penalty: What is the Definition of Willfulness?IRS FBAR Willful Penalties Defined, and how IRS Proves Taxpayer Willfulness.