I have previously written on the Bittner (E.D. Tex.) case in a prior Insight. Briefly summarized, the taxpayer, Mr. Bittner, was a dual citizen of both Romania and the United States. However, in 1990, he moved back to...more
10/10/2020
/ Appeals ,
Business Taxes ,
Calculation of Penalties ,
Civil Monetary Penalty ,
Congressional Intent ,
Cross Motions ,
Dual Citizenship ,
Failure-to-File ,
FBAR ,
Foreign Bank Accounts ,
Genuine Issue of Material Fact ,
Income Taxes ,
IRS ,
Reasonable Cause Defense ,
Reporting Requirements ,
Romania ,
Rule of Lenity ,
Summary Judgment ,
United States