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How Does the IRS Define Willfulness in Unreported or Under-reported Offshore Income?

How does the IRS define willfulness in unreported or under-reported offshore income?  What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct?  Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful?  If you have accounts with any Foreign Financial Institutions...