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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In Norman, the Federal Circuit held that a presently out-of-date Treasury Regulation did not cap FBAR penalties for unrelenting offenses at $100,000. Law 7(b)( 1) Mot. Mr. Mendu remembers that, because of the reality that this Court does not have independent area over the Defendant’s counterclaim for $752,920, this Court needs to overlook the Defendant’s counterclaim.

Policy 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 must overlook the Defendant’s counterclaim.

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