United States v. McBride

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER

DAVID NUFFER, District Judge.

Plaintiff United States of America brought this case to collect a civil penalty assessed to Defendant Jon McBride for his alleged willful failure to report his interest in four foreign bank accounts during tax years 2000 and 2001 as required under 31 U.S.C. § 5314 and related regulations. The matter was tried to the bench on May 21-22, 2012, and the court took the matter under -advisement. The parties have submitted competing proposals as to the facts and legal conclusions that should be reached.1 Having carefully…