United States v. Eli Chabot

OPINION OF THE COURT

RESTANI, Judge.

Eli and Renee Chabot (“the Chabots”) appeal the District Court’s grant of the Internal Revenue Service’s (“IRS”) petition to enforce summonses for foreign bank account records that 31 C.F.R. § 1010.420 requires the Chabots to keep. Today we join six other circuits in holding that these records fall within the required records exception to the Fifth Amendment privilege. Accordingly, we will affirm the District Court’s grant of the IRS’s petition.

I. Background

In April 2010, the IRS received information from French authorities concerning United States persons 1…