Legal Opinion
Arthur Bedrosian v. United States
Court of Appeals for the Third Circuit
Decided December 21, 2018No. 17-3525PublishedCited by 57 opinions
1Opinion of the Court
AMBRO, Circuit Judge This appeal presents two issues of first impression in our Court concerning the Internal Revenue Service's assessment of civil penalties for violation of 31 U.S.C. § 5314 and its implementing regulations, which require certain persons annually to file a Report of Foreign Bank and Financial Accounts (colloquially called a "FBAR" or simply "Report"). First, we examine federal court jurisdiction over actions challenging the IRS's assessment of civil FBAR penalties. We conclude that jurisdiction exists here but reserve the question whether it is established in the District…
2Cases cited28 opinions
- Farmer v. BrennanSupreme Court of the United States · 1994
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Safeco Insurance Co. of America v. BurrSupreme Court of the United States · 2007
- United States v. BoyleSupreme Court of the United States · 1985
- Flora v. United StatesSupreme Court of the United States · 1960
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3Cited by57 opinions
- Linda Stone v. Troy Construction LLCCourt of Appeals for the Third Circuit · 2019
- Jessica Ramsay v. National Board of Medical ExamCourt of Appeals for the Third Circuit · 2020
- United States v. Peter HorowitzCourt of Appeals for the Fourth Circuit · 2020
- Norman v. United StatesCourt of Appeals for the Federal Circuit · 2019
- United States v. Said RumCourt of Appeals for the Eleventh Circuit · 2021
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