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U.S. v. WILLIAMS

No. 10-2230.

UNITED STATES OF AMERICA, Plaintiff-Appellant, v. J. BRYAN WILLIAMS, Defendant-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided: July 20, 2012.

Attorney(s) appearing for the Case

ARGUED: Robert William Metzler, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellant.

David Harold Dickieson, SCHERTLER & ONORATO, LLP, Washington, D.C., for Appellee.

ON BRIEF: John A. DiCicco, Acting Assistant Attorney General, Deborah K. Snyder, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Neil H. MacBride, United States Attorney, Alexandria, Virginia, for Appellant.

Lisa H. Schertler, SCHERTLER & ONORATO, LLP, Washington, D.C., for Appellee.

Reversed by unpublished opinion. Judge Shedd wrote the majority opinion, in which Judge Motz concurred. Judge Agee wrote a dissenting opinion.

Unpublished opinions are not binding precedent in this circuit.

SHEDD, Circuit Judge

The Government brought this action seeking to enforce civil penalties assessed against J. Bryan Williams for his failure to report his interest in two foreign bank accounts for tax year 2000, in violation of 31 U.S.C. § 5314. Following a bench trial, the district court entered judgment in favor of Williams. The Government now appeals. Because we conclude...

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