Ponder this as you’re raging against the insane penalties handed out by the IRS like stale Girl Scout cookies: it is constitutional for the government to kill you.
Don’t waste your time thinking about this unless you’re willing to dump a couple of million bucks into a lawyer’s wallet to fight this up to the Supreme Court. And that lawyer is not me. I don’t have that skill-set.
Mention a constitutional argument against the OVDI or FBAR penalties and the IRS Commissioner is going to choke on his martini laughing at you.
Sorry, L. It has to be said. But my suggestion in my email to you still stands, and I think it has a far greater possibility of success.