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UNITED STATES v. BOYD

No. 19-55585.

991 F.3d 1077 (2021)

UNITED STATES of America, Plaintiff-Appellee, v. Jane BOYD, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed March 24, 2021.

Attorney(s) appearing for the Case

A. Lavar Taylor , (argued) and Jonathan T. Amitrano , Law Offices of A. Lavar Taylor LLP, Santa Ana, California, for Defendant-Appellant.

Francesca Ugolini , (argued), Deborah K. Snyder , and Kathleen E. Lyon , Attorneys; Richard E. Zuckerman , Principal Deputy Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Plaintiff-Appellee.

David Michaels , DTMtax, Placentia, California, for Amici Curiae Laxman, Jashu, Hiten, and Anita Patel.

Caroline D. Ciraolo , and Caroline Rule , Kostelanetz & Fink LLP, Washington, D.C., for Amicus Curiae American College of Tax Counsel.

Dissent by Judge Ikuta.

OPINION

Defendant Jane Boyd did not timely file a Report of Foreign Bank and Financial Accounts form ("FBAR") disclosing her foreign financial accounts in the United Kingdom.1 The Internal Revenue Service ("IRS") found that she violated the reporting requirements of 31 U.S.C. §...

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