United States v. Zhong H. Chen

LYNCH, Circuit Judge.

Tensions between taxpayers and the Internal Revenue Service (“IRS”) over forced disclosure of foreign bank account information implicate both statutory and constitutional rights. Taxpayers have Fifth Amendment rights not to be forced to incriminate themselves by the compelled act of production. But where the documents are required to be kept under the regulatory scheme of the Bank Secrecy Act (“BSA” or “the Act”), see Currency and Foreign Transactions Reporting Act, Pub. L. No. 91-508, tit. II, 84 Stat. 1118 (1970) (codified as amended at 31 U.S.C. § 5311 et seq.), the…