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UNITED STATES v. TOTH

No. 21-1009.

33 F.4th 1 (2022)

UNITED STATES of America, Appellee, v. Monica TOTH, Defendant, Appellant.

United States Court of Appeals, First Circuit.

April 29, 2022.

Attorney(s) appearing for the Case

Jeffrey P. Wiesner , with whom Jennifer McKinnon and Wiesner McKinnon LLP were on brief, for appellant.

Jennifer M. Rubin , Tax Division, Department of Justice, with whom David A. Hubbert , Acting Assistant Attorney General, Francesca Ugolini , Tax Division, Department of Justice, and Bruce R. Ellisen , Tax Division, Department of Justice, were on brief, for appellee.

Before Barron, Chief Judge, Lynch and Lipez, Circuit Judges.

In 2013, the U.S. Internal Revenue Service ("IRS") ordered the imposition of a penalty of over $2 million against Monica Toth for willfully failing to report her Swiss bank account in violation of the Bank Secrecy Act ("Act"). See 31 U.S.C. § 5314(a). Toth contested the penalty and refused to pay...

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