Bittner v. United States — does the 2023 Supreme Court ruling cap my non-willful FBAR exposure?
I missed FBAR filings for 4 years and held 8 foreign accounts each year. The IRS first proposed stacking penalties per account per year — that would have been a six-figure number. A friend mentioned Bittner v. United States changed the math. What did the Supreme Court actually hold and does it apply to my case?
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