Wow, finally somebody who nearly correctly reports the facts !

FBAR Penalties
This past year the government brought a case against Carl R. Zwerner of Miami for willful failure to file foreign bank account reports. The penalties were originally assessed at 4x50% willful penalty or 3 times the value of the undisclosed account that Mr. Zwerner held offshore. The case was taken to trial, and the jury found for the government for about 150% (3x50% willful penalty) of the value of the account. The jury was also asked to decide whether the FBAR penalties were constitutional under the Eighth Amendment. On the eve of a hearing on the issue, the case was settled and Mr. Zwerner agreed to pay 100% (2x50% willful penalty) of the value of the account.
The case shows that the government won't be a "shrinking violet" in bringing similar judicial action, said Michel.
The case will likely raise government concerns about the Constitution argument, because in light of existing case law it is hard to imagine that a similar case wouldn't raise judges' eyebrows when a penalty exceeds the value of the taxpayer's assets, said Michel.
http://www.capdale.com/scott-michel-comments-on-us-strengthening-international-tax-enforcement-efforts