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UNITED STATES v. BITTNER

No. 20-40597.

19 F.4th 734 (2021)

UNITED STATES of America, Plaintiff-Appellee/Cross-Appellant, v. Alexandru BITTNER, Defendant-Appellant/Cross-Appellee.

United States Court of Appeals, Fifth Circuit.

Filed November 30, 2021.

Attorney(s) appearing for the Case

Paul Andrew Allulis, Attorney, Arthur Thomas Catterall, U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, for Plaintiff-Appellee/Cross-Appellant.

Farley P. Katz, Rachael E. Rubenstein, Clark Hill, P.L.C., San Antonio, TX, for Defendant-Appellant/Cross-Appellee.

Before OWEN, Chief Judge, and CLEMENT and DUNCAN, Circuit Judges.

Alexandru Bittner non-willfully failed to report his interests in foreign bank accounts on annual FBAR forms, as required by the Bank Secrecy Act of 1970 (BSA) and regulations thereunder. See 31 U.S.C. § 5314; 31 C.F.R. §§ 1010.306, 1010.350. The government assessed $2.72 million in civil...

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