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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. Policy 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 fines for unyielding infractions at $100,000. Policy 7(b)( 1) Mot. Regulation 7(b)( 1) Mot. Mr. Mendu keeps in mind that, since this Court does not have independent territory over the Defendant’s counterclaim for $752,920, this Court needs to disregard the Defendant’s counterclaim. Policy 7(b)( 1) Mot.

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