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The taxpayer failed to report approximately 2 000 of interest income from the account and is therefore unable to simply file a delinquent FBAR for 2007 as provided in FAQ 17. The tax deficiency was 700. In addition assume the taxpayer does not otherwise qualify for a reduced penalty under FAQ 52 or 53. The taxpayer was unaware of his FBAR filing obligation until having his return professionally prepared in 2008. The taxpayer failed to report appr.

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