The Bank Secrecy Act (BSA) and its implementing regulations require United States persons with certain financial interests in foreign accounts to file an annual report know as an FBAR (the Report of Foreign Bank and Financial Accounts). The BSA authorizes the Secretary to impose a civil penalty up to $10,000 for non-willful violations of the law.
In Bittner v. U.S, the taxpayer filed late FBARs for the 2007 through 2011 years and the government deemed Bittner’s late-filed FBARs deficient because…
