Supreme Court FBAR Hearing November 2, 2022: ALEXANDRU BITTNER, Petitioner, v. No. 21-1195 UNITED STATES, Respondent

On November 2, 2022 the Supreme Court Of The United States heard the Bittner case. The issue was whether in the context of a non-willful FBAR penalty:

1) The government is restricted to imposing one penalty based on the failure to file one FBAR; or

 

2) The government may impose one non-willful penalty for each of the accounts that should have been reported on the single FBAR form.

This podcast contains the audio file of the live arguments.

A transcript of the arguments is here:

http://citizenshipsolutions.ca/wp-content/uploads/2022/11/21-1195_5i36.pdf

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The FBAR penalties imposed on Mr. Bittner were based on years when he was a US citizen living outside the United States in Romania. Therefore, this decision is hugely important for the community of Americans abroad.

I have previously discussed the Bittner case in podcasts with:

Virginia La Torre Jeker - October 31, 2022

Jimmy Sexton - November 1, 2022

Anthony Parent - November 1, 2022

 

The following twitter thread reflects my impressions while listening to the arguments ...

https://threadreaderapp.com/thread/1587807427327655937.html