Did the Court err in holding that Alice acted willfully, despite the lack of proof either that she had knowledge of the requirement to file an FBAR or of her intent to evade taxes?

QUESTIONS PRESENTED 1. Did the Court err in holding that Alice acted willfully, despite the lack of proof either that she had knowledge of the requirement to file an FBAR or of her intent to evade taxes? 2. Did the Court’s finding of willfulness despite lack of proof of intent or knowledge improperly interpret the statute by rendering every failure to file willful, although the statute (31 U.S.C. §§5321) provides differing penalties for willful and non-willful violations? 8. Did the Court err in finding that the Respondent properly assessed the maximum penalty on the Petitioner’s foreign bank account, in light of the substantial proof of the fact that the Respondent relied upon erroneous findings of fact, and that the assessment of the penalty was punitive? 4. Did the Court err in holding that Alice did not preserve her argument that the 50% penalty imposed upon her account was an Excessive Fine under the Eighth Amendment to the United States Constitution? 5. Was the penalty imposed upon Alice’s account ($697,229) an Excessive Fine under the Eighth Amendment to the United States Constitution? 6. Did the Court err in finding that the amendments to the law [31 U.S.C. §5321(a)(5)(C)()] superseded IRS regulation [31 CFR §1010.820] regarding the maximum penalty that can be imposed by the IRS after a finding of a willful failure to file Foreign Bank Account Report (“FBAR”)?