BRYSON, Circuit Judge.
In 1990, the government filed a complaint in the Court of International Trade against Jac Natori Co., Ltd., an importer. The complaint sought to recover penalties based on allegedly inaccurate entry forms filed with a shipment of goods in 1985, penalties based on fraud in connection with entries in 1981 and 1982, and unpaid duties resulting from the 1981 and 1982 entries. After trial, the Court of International Trade awarded the government penalties...
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