Toth has already made amends and paid fines for her mistakes with her IRS filings. In absence of evidence of deliberate fraud, it's hard not to see this grasping as anything other than an attempt by the IRS and the Department of Treasury to bring in some money. The Institute for Justice notes that Toth is far from alone here. There's been a recent escalation in the use of civil penalties by the federal government over FBAR filings: "Over the past decade, the government has expanded its FBAR enforcement relentlessly. Between 2012 and 2020, it assessed nearly $1.5 billion in FBAR penalties. This Term, it is asking the Court to ratify a still more aggressive regime."
