The Supreme Court today granted certiorari in the Bittner case to address the issue of whether the FBAR nonwillful penalty is per form or per account. See Order List, p. 2, here. I covered the key points at this stage in a prior blog. Solicitor General Acquiesces in Bittner Petition for Cert on Issue of FBAR Nonwillful Penalty Per Form or Per Account (Federal Tax Crimes Blog 5/19/22), here. So I will defer further comment now.
The docket entries where the briefings and other documents as they are filed may be retrieved in the following web pages:
- Supreme Court here.
- Scotusblog here (Note, as of this posting the cert granted entry has not been posted but should be posted by the end of the day.