Before Prost, Chief Judge, Moore and Wallach, Circuit Judges.
Prost, Chief Judge.
Mindy P. Norman appeals a July 31, 2018 decision by the U.S. Court of Federal Claims finding that: (a) Ms. Norman willfully failed to file a Report of Foreign Bank and Financial Accounts ("FBAR") in 2007; and (b) the Internal Revenue Service ("IRS") properly assessed a penalty of $803,530 for this failure. For the reasons stated...
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