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Are FBAR Penalties Taxes for Purposes of the Flora Rule?

In Norman, the Federal Circuit held that a presently out-of-date Treasury Regulation did not cap FBAR penalties for stubborn offenses at $100,000. Guideline 7(b)( 1) Mot. Mr. Mendu bears in mind that, as a result of the reality that this Court does not have independent region over the Defendant’s counterclaim for $752,920, this Court needs to neglect the Defendant’s counterclaim.

Policy 7(b)( 1) Mot. Mr. Mendu maintains in mind that, due to the reality that this Court does not have independent region over the Defendant’s counterclaim for $752,920, this Court ought to overlook the Defendant’s counterclaim.

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