. . "u look at what the question asks, and the answer would be clearly no, for two reasons.1) the FBAR penalty is not a tax but a penalty based on Title 31, not Title 26 which is the tax code.2) Something cannot be outstanding or unpaid until a) they say you owe it, which would occur only at the time the form 906 is signed by both parties or you do not sign and they assess a penalty AND b) there is a pr" . .