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Are FBAR Penalties Taxes for Purposes of the Flora Rule?

In Norman, the Federal Circuit held that a currently obsolete Treasury Regulation did not cap FBAR fines for unyielding offenses at $100,000. Regulation 7(b)( 1) Mot. Mr. Mendu keeps in mind that, due to the fact that this Court does not have independent territory over the Defendant’s counterclaim for $752,920, this Court has to disregard the Defendant’s counterclaim.

In Norman, the Federal Circuit held that a currently obsolete Treasury Regulation did not cap FBAR charges for unyielding infractions at $100,000. Policy 7(b)( 1) Mot. Regulation 7(b)( 1) Mot. Mr. Mendu keeps in mind that, due to the fact that this Court does not have independent territory over the Defendant’s counterclaim for $752,920, this Court should disregard the Defendant’s counterclaim. Regulation 7(b)( 1) Mot.

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