Draft:Bittner v. United States

Bittner v. United States, 598 U.S. 85 (2023), was a United States Supreme Court case related to the penalty for multiple failures to report a foreign bank account. After the fall of communism in Romania, Alexandru Bittner, a naturalized American citizen, returned to his native country and became a businessman, but failed to report his foreign bank accounts to the Internal Revenue Service (IRS), as required by the Bank Secrecy Act. He later filed corrected reports for 2007-2011. Under statutory law, the government is authorized to fine a maximum penalty of $10,000 for non-willful failure to report a foreign bank account. Because the number of accounts over 5 years totaled 272, the government sought to fine Mr. Bittner $2.72 million. The case was notable for the resulting "strange lineup of justices" which did not split along traditional ideological lines.