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BEDROSIAN v. U.S. DEPT. OF THE TREASURY, IRS

No. 17-3525.

912 F.3d 144 (2018)

Arthur BEDROSIAN v. UNITED STATES OF AMERICA, DEPARTMENT OF THE TREASURY, INTERNAL REVENUE SERVICE, Appellant.

United States Court of Appeals, Third Circuit.

Opinion filed: December 21, 2018.

Attorney(s) appearing for the Case

Richard E. Zuckerman, Principal Deputy Assistant Attorney General, Travis A. Greaves, Deputy Assistant Attorney General, Gilbert S. Rothenberg, Esquire, Francesca Ugolini, Esquire, Andrew M. Weiner, Esquire (Argued), United States Department of Justice, Tax Division, 950 Pennsylvania Avenue, N.W., P.O. Box 502, Washington, DC, 20044, Counsel for Appellant.

Patrick J. Egan, Esquire (Argued), Beth L. Weisser, Esquire, Fox Rothschild, 2000 Market Street, 20th Floor, Philadelphia, PA 19103, Counsel for Appellee.

Before: AMBRO, CHAGARES, and GREENAWAY, JR., Circuit Judges.

OPINION OF THE COURT

This appeal presents two issues of first impression in our Court concerning the Internal Revenue Service's assessment of civil penalties for violation of 31 U.S.C. § 5314 and its implementing regulations, which require certain persons annually to file a Report of Foreign Bank and Financial...

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