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Are FBAR Penalties Taxes for Purposes of the Flora Rule?

In Norman, the Federal Circuit held that a presently out-of-date Treasury Regulation did not cap FBAR fees for stubborn offenses at $100,000. Standard 7(b)( 1) Mot. Mr. Mendu remembers that, as a result of the truth that this Court does not have independent area over the Defendant’s counterclaim for $752,920, this Court requires to deny the Defendant’s counterclaim.

Standard 7(b)( 1) Mot. Mr. Mendu maintains in mind that, due to the truth that this Court does not have independent area over the Defendant’s counterclaim for $752,920, this Court has to deny the Defendant’s counterclaim.

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