942 F.3d 1111 (2019)

Mindy P. NORMAN, Plaintiff-Appellant v. UNITED STATES, Defendant-Appellee

United States Court of Appeals, Federal Circuit.

Decided: November 8, 2019.

Attorney(s) appearing for the Case

Paula Schwartz Frome , Garden City, NY, argued for plaintiff-appellant.

Deborah K. Snyder , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellee. Also represented by Geoffrey Klimas , Richard E. Zuckerman , Travis A. Greaves , Gilbert Steven Rothenberg .

Before Prost, Chief Judge, Moore and Wallach, Circuit Judges.

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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