This is the property of the Daily Journal Corporation and fully protected by copyright. It is made available only to Daily Journal subscribers for personal or collaborative purposes and may not be distributed, reproduced, modified, stored or transferred without written permission. Please click "Reprint" to order presentation-ready copies to distribute to clients or use in commercial marketing materials or for permission to post on a website. and copyright (showing year of publication) at the bottom.
Subscribe to the Daily Journal for access to Daily Appellate Reports, Verdicts, Judicial Profiles and more...

U.S. v. Boyd

Ruling by

Mark J. Bennett

Lower Court

USDC Central District of California

Lower Court Judge

Michael W. Fitzgerald

dissenting Judge(s)

Sandra S. Ikuta
31 U.S.C. Section 5321(a)(5)(A) authorizes IRS to impose only one non-willful penalty when an untimely, but accurate, Foreign Bank and Financial Accounts form is filed, no matter number of accounts.



To continue reading, please subscribe.

Already a subscriber?