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For years, FBAR litigants have made the commonsense argument that large willful FBAR penalties, which can exceed the value of the unreported foreign accounts themselves, violate the excessive fines ...

Paul G. Summers, a lawyer, is a former appellate and senior judge, district attorney general, and the attorney general of Tennessee. Editor's note: This is a regular feature on issues related to the ...

The prior-panel-precedent rule allows federal appellate courts to avoid considering “difficult arguments” and “to do its work with fewer judges more quickly,” said a legal scholar who is not involved ...

The Eleventh Circuit held that three penalties of 23 assessed against a taxpayer for failure to file Financial Crimes Enforcement Network (FinCEN) Form 114, Report of Foreign Bank and Financial ...