Eleventh Circuit affirms Tax Court lacks jurisdiction over FBAR penalty collection

Jenner v. Commissioner, No. 25-10014, 2025 BL 438147. Court Opinion.

FBAR penalties are not taxes. Taxpayers cannot use the Tax Court collection due process procedures to challenge them.

Holding

The Eleventh Circuit affirmed the Tax Court’s dismissal for lack of jurisdiction. The Tax Court has no authority to review FBAR penalties or administrative offsets used to collect them.

Why It Matters

• FBAR penalties arise under Title…