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July 07, 2009


A. Rubinstein

It does seem to be a late effort tactic to stall oral argument next week.

However, the Government's brief is wrong on the following: "What is indisputable, however, is that the filing of a Foreign Bank
Account Report (FBAR) or the submission of paperwork to voluntarily disclose an “undeclared” UBS account does not require the U.S. taxpayer to produce any of the UBS-sourced documents that the IRS seeks in the summons at issue here." (p.3 of Petitioner's Memorandum in Opposition).

This is not correct. Under the Voluntary Disclosure program, the taxpayer agrees to cooperate fully, and if the IRS requests UBS statements or other documentation, the taxpayer would have to provide it (assuming he had it . . . and if didn't have it, the IRS would require him to request it from UBS).

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