The penalties for fara violations can exceed the maximum amount of money in the account. The finest are basically asset seizure.
The IRS should make a deal with the whistleblowers and then continue with the case discovery.
Civil tax fraud
No statute of limitations: For civil tax fraud cases, the IRS generally has an unlimited amount of time to assess taxes and penalties related to fraudulent activities. This means they can go back as far as needed to pursue unpaid taxes if fraud was involved.
Proof of fraud required: To apply the unlimited statute of limitations, the IRS must prove that the taxpayer filed a false or fraudulent return with the intent to evade taxes.
If no return was filed, the statute of limitations does not start.
Fara violations are not tax code violations.