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UNITED STATES v. SCHWARZBAUM

No. 20-12061.

24 F.4th 1355 (2022)

UNITED STATES of America, Defendant-Appellee, v. Isac SCHWARZBAUM, Plaintiff-Appellant.

United States Court of Appeals, Eleventh Circuit.

January 25, 2022.

Attorney(s) appearing for the Case

Stacy Delayne Blank , Andrea Darling de Cortes , William Morris Sharp , Chad M. Vanderhoef , Holland & Knight, LLP, Tampa, FL, Jose Angel Casal , Daniel Ira Small , Holland & Knight, LLP, Miami, FL, James P. Dawson , Holland & Knight, LLP, West Palm Beach, FL, Nicole M. Elliott , Holland & Knight, LLP, Washington, DC, for Plaintiff-Appellant.

Clint A. Carpenter , Francesca Ugolini , U.S. Department of Justice, Appellate Section Tax Division, Washington, DC, John Paul Nasta , Michael N. Wilcove , U.S. Department of Justice, Tax Division, Washington, DC, Jeffrey N. Nunez , Mary Elizabeth Smith , U.S. Department of Justice, Washington, DC, Emily M. Smachetti , U.S. Attorney's Office, Miami, FL, U.S. Attorney Service — Southern District of Florida, U.S. Attorney Service — SFL, Miami, FL, for Defendant-Appellee.

Before Branch, Grant, and Brasher, Circuit Judges.

Every year, U.S. citizens with over $10,000 in foreign bank accounts must disclose information about those accounts to the IRS on a Report of Foreign Bank and Financial Accounts or "FBAR" form. For several years in the early 2000s, Isac Schwarzbaum did not. After the IRS discovered Schwarzbaum's omissions, and determined that...

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