Bittner v. United States (598 U.S. 85)
U.S. Supreme Court · decided February 28, 2023 · Supreme Court Database (Spaeth)
- Citation
- 598 U.S. 85 · 143 S. Ct. 713
- Decided
- February 28, 2023
- Term
- October Term 2022
- Vote
- 5–4
- Majority author
- Justice Gorsuch
- Issue area
- Federal Taxation
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
PRELIMINARY PRINT Volume 598 U. S. Part 1 Pages 85–114 OFFICIAL REPORTS OF THE SUPREME COURT February 28, 2023 Page Proof Pending Publication REBECCA A. WOMELDORF reporter of decisions NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D.C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. OCTOBER TERM, 2022 85 Syllabus BITTNER v. UNITED STATES certiorari to the united states court of appeals for the fth circuit No. 21–1195. Argued November 2, 2022—Decided February 28, 2023 The Bank Secrecy Act (BSA) and its implementing regulations require U. S. persons with certain fnancial interests in foreign accounts to fle an annual report known as an “FBAR”—the Report of Foreign Bank and Financial Accounts. The statute imposes a maximum $10,000 pen- alty for nonwillful violations of the law. These reports are designed to help the government trace funds that may be used for illicit purposes and identify unreported income that may be subject to taxation. Peti- tioner Alexandru Bittner—a dual citizen of Romania and the United States—learned of his BSA reporting obligations after he returned to the United States from Romania in 2011, and he subsequently submitted the required annual reports covering fve years (2007…
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