United States v. Bohanec

*883FINDINGS OF FACT AND CONCLUSIONS OF LAW

DEAN D. PREGERSON, UNITED STATES DISTRICT JUDGE

Plaintiff, - United States of America, seeks to collect a civil penalty assessed to Defendants August Bohanec and Maria Bohanec (collectively, “Defendants” or “the Bohances”) for willful failure to report their interest in foreign bank accounts during tax year 2007, as required under 31 U.S.C. § 5314 and its implementing regulations. This matter was tried before the court on November 1,2016. Having considered the submissions and arguments of the parties, as well as the evidence in the record, the court…