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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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