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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 charges for unrelenting offenses at $100,000. Regulation 7(b)( 1) Mot. Mr. Mendu keeps in mind that, as an outcome of the reality that this Court does not have independent location over the Defendant’s counterclaim for $752,920, this Court requires to forget the Defendant’s counterclaim.

Plan 7(b)( 1) Mot. Mr. Mendu preserves in mind that, as a result of the reality that this Court does not have independent area over the Defendant’s counterclaim for $752,920, this Court should certainly disregard the Defendant’s counterclaim.

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