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.
STUART KYLE DUNCAN, Circuit Judge.
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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