| Bittner v. United States | |
|---|---|
 Supreme Court of the United States | |
| Argued November 2, 2022 Decided February 28, 2023 | |
| Full case name | Bittner v. United States |
| Docket no. | 21-1195 |
| Citations | 598 U.S. 85 (more) |
| Holding | |
| The penalty for non-willful failure to report a bank account under the Bank Secrecy Act applies once per failed report, not once per account. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Gorsuch, joined by Jackson; Roberts, Alito, Kavanaugh (except part II-C) |
| Dissent | Barrett, joined by Thomas, Sotomayor, Kagan |
Bittner v. United States, 598 U.S. 85 (2023), was a United States Supreme Court case related to the penalty for multiple failures to report a foreign bank account. After the fall of communism in Romania, Alexandru Bittner, a naturalized American citizen, returned to his native country and became a businessman, but failed to report his foreign bank accounts to the Internal Revenue Service (IRS), as required by the Bank Secrecy Act. He later filed corrected reports for 2007-2011. Under statutory law, the government is authorized to fine a maximum penalty of $10,000 for non-willful failure to report a foreign bank account. Because the number of accounts over 5 years totaled 272, the government sought to fine Mr. Bittner $2.72 million. The case was notable for the resulting "strange lineup of justices" which did not split along traditional ideological lines.
References
- "Bittner v. United States, 598 U.S. ___ (2023)". Justia Law. Retrieved 2024-06-21.
- "Strange lineup of justices limits penalties for failure to file reports about foreign bank accounts". SCOTUSblog. 2023-02-28. Retrieved 2024-06-21.
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