United States of America v. Fariba Ely Cohen

Filing 101

JUDGMENT by Judge Michael W. Fitzgerald. IT ORDERED that Fariba Cohen is liable to the United States for the full amount of the assessed FBAR penalty of $1,549,849.00 under 31 U.S.C. 5321 for the year 2008, plus the late payment penalty and interest pursuant to 31 U.S.C. 3717 that continue to accrue from the date of assessment on March 5, 2015. (MD JS-6, Case Terminated). (iv)

1
2
3

JS-6

4
5
6
7
8
9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11

WESTERN DIVISION

12
13

UNITED STATES OF AMERICA,

Case No. CV 17-1652 MWF (JCx)

Plaintiff,

14
15

v.

16

JUDGMENT

FARIBA ELY COHEN,

Defendant.

17
18
19
20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///
1

1
2
3

Based on the Stipulation to reduce FBAR penalty to judgment, and for
good cause appearing:
IT ORDERED that Fariba Cohen is liable to the United States for the

4

full amount of the assessed FBAR penalty of $1,549,849.00 under 31 U.S.C.

5

§ 5321 for the year 2008, plus the late payment penalty and interest

6

pursuant to 31 U.S.C. § 3717 that continue to accrue from the date of

7

assessment on March 5, 2015. Post-judgment interest shall accrue as allowed

8

by law pursuant to 28 U.S.C. § 1961. The late payment penalty pursuant to

9

31 U.S.C. § 3717 continues to accrue post-judgment. Entry of judgment shall

10

resolve all issues in the case.

11

IT IS FURTHER ORDERED that as of February 3, 2022, the balance

12

due was $2,300,952.54, consisting of the FBAR penalty of $1,549,849, failure

13

to pay penalty of $643,803.03, and interest of $107,300.51. Interest and

14

penalties continue to accrue.

15

IT IS FURTHER ORDERED that if Fariba Cohen pays the United

16

States the Settlement Amount in full as described below, on or before

17

January 31, 2024, the United States will file and record a satisfaction of

18

judgment. The Settlement Amount equals 60% of the assessed FBAR

19

penalty, which is $929,909 ($1,549,849 x 60%) (the “Settled FBAR Penalty”)

20

plus statutory penalties and interest as set forth above that have accrued on

21

that amount from the date of assessment, or will accrue on the Settled FBAR

22

Penalty to the date of full payment of the Settled FBAR Penalty (collectively,

23

the “Settlement Amount”).

24

IT IS FURTHER ORDERED that the United States shall not seek to

25

enforce the entered judgment during the settlement period, which shall be

26

from the date of entry of judgment to January 31, 2024. However, an

27

abstract of judgment may be recorded by the United States.

28
2

1

IT IS FURTHER ORDERED that payment(s) shall be made by

2

cashier’s check made payable to the United States Treasury and delivered to:

3
4
5
6
7
8
9
10
11
12
13

AUSA Gavin Greene
Federal Building
300 N. Los Angeles Street, Room 7211
Los Angeles, California 90012
IT IS FURTHER ORDERED that the parties will bear their own
costs and expenses, including any attorney fees.
IT IS FURTHER ORDERED that the final pretrial conference and
trial dates are VACATED.
IT IS SO ORDERED.
Dated: April 6, 2022

____________________________
MICHAEL W. FITZGERALD
United States District Judge

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3