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BEDROSIAN v. UNITED STATES DEPARTMENT OF TREASURY

No. 21-1583.

42 F.4th 174 (2022)

Arthur BEDROSIAN, Appellant, v. The UNITED STATES of America, DEPARTMENT OF the TREASURY, INTERNAL REVENUE SERVICE.

United States Court of Appeals, Third Circuit.

Opinion filed: July 22, 2022.

Attorney(s) appearing for the Case

Ian M. Comisky [Argued], Siana Danch , Patrick J. Egan , Beth L. Weisser , Fox Rothschild , 2000 Market Street, 20th Floor, Philadelphia, PA 19103, Counsel for Appellant.

Paul A. Alluis [Argued], Michael J. Haungs , United States Department of Justice, Tax Division, 950 Pennsylvania Avenue, N.W., P.O. Box 502, Washington, DC 20044, Francesca Ugolini , United States Department of Justice, Tax Division, Room 4633, 950 Pennsylvania Avenue, N.W., P.O. Box 502, Washington, DC 20044, Counsel for Appellee.

Before: McKEE, AMBRO, and SMITH, Circuit Judges.

OPINION OF THE COURT

The Bank Secrecy Act, 31 U.S.C. § 5311 et seq., and its implementing regulations require certain individuals with foreign financial interests to file annual disclosures with the U.S. Treasury Department. Those failing to file or filing inaccurate reports are subject to hefty penalties...

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