The National Taxpayer Advocate's report discussed in the preceding blog has a component titled Most Litigated Issues: Case Advocacy, Appendices, here.  In that component, the NTA discussed the Williams case (see report at pp 601 - 603).  The discussion is (footnotes omitted):

The National Taxpayer Advocate's report discussed in the preceding blog has a component titled Most Litigated Issues: Case Advocacy, Appendices.  In that component, the NTA discussed the Williams case (see report at pp 601 - 603).  The discussion is a good review for students and practitioners...

The discussion is (footnotes omitted):

In United States v. Williams, the District Court for the Eastern District of Virginia held that the government did not prove that a taxpayer's failure to report his foreign accounts on a Report of Foreign Bank and Financial Accounts (FBAR) was willful, even though Schedule B of his income tax return indicated that he had no foreign accounts and he acknowledged willfully failing to report income from the accounts on his return.

Mr. Williams, a U.S. citizen and New York University-trained lawyer, pled guilty to tax evasion and criminal conspiracy to defraud the government with respect to more than $7 million in unreported income that he deposited in foreign accounts and more than $800,000  in earnings on those deposits.  in connection with this plea, Mr. Williams admitted that he intentionally failed to report income in an effort to evade income taxes between 1993 and 2000.  Acting on a request from the U.S., the Swiss government froze his accounts in 2000...

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