No. 21-1195
Alexandru Bittner v. United States
Tags: bank-secrecy-act civil-penalty fbar fbar-reporting foreign-accounts penalty-assessment per-account per-form statutory-construction treasury-regulations
Latest Conference:
2022-06-16
(distributed 2 times)
Question Presented (from Petition)
Whether a "violation" under the Act is the failure to file an annual FBAR (no matter the number of foreign accounts), or whether there is a separate violation for each individual account that was not properly reported.
Question Presented (AI Summary)
Whether a 'violation' under the Bank Secrecy Act is the failure to file an annual FBAR (no matter the number of foreign accounts), or whether there is a separate violation for each individual account that was not properly reported
Docket Entries
2023-04-03
Judgment issued.
2023-02-28
Judgment REVERSED and case REMANDED. Gorsuch, J., announced the judgment of the Court, and delivered the opinion of the Court except as to Part II–C. Jackson, J., joined that opinion in full, and Roberts, C. J., and Alito and Kavanaugh, JJ., joined except for Part II–C. Barrett, J., filed a dissenting opinion, in which Thomas, Sotomayor, and Kagan, JJ., joined.
2022-11-02
Argued. For petitioner: Daniel L. Geyser, Dallas, Tex. For respondent: Matthew Guarnieri, Assistant to the Solicitor General, Department of Justice, Washington, D. C.
2022-10-21
Reply of petitioner Alexandru Bittner filed. (Distributed)
2022-10-06
Brief amicus curiae of National Whistleblower Center filed. (Distributed)
2022-09-30
Brief of respondent United States filed. (Distributed)
2022-09-12
The record from the U.S.C.A. 5th Circuit is electronic and located on Pacer.
2022-09-12
Record requested from the U.S.C.A. 5th Circuit.
2022-08-31
CIRCULATED
2022-08-25
Brief amicus curiae of The Chamber of Commerce of the United States of America filed.
2022-08-25
Brief amicus curiae of Center for Taxpayer Rights filed.
2022-08-24
Brief amicus curiae of American College of Tax Counsel in support of neither party filed.
2022-08-23
Brief amici curiae of National Federation of Independent Business Small Business Legal Center, et al. filed.
2022-08-18
Joint appendix filed. (Statement of costs filed)
2022-08-18
Brief of petitioner Alexandru Bittner filed.
2022-08-17
Further extension of time to file petitioner's brief on the merits to and including August 18, 2022. Further extension of time to file respondent's brief on the merits to and including September 30, 2022.
2022-08-16
Brief amicus curiae of American College of Trust and Estate Counsel in support of neither party filed.
2022-08-03
Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioner's brief on the merits is extended to and including August 17, 2022. The time to file respondent's brief on the merits is extended to and including September 28, 2022.
2022-08-03
ARGUMENT SET FOR Wednesday, November 2, 2022.
2022-07-28
Motion for an extension of time to file the briefs on the merits filed.
2022-07-28
Blanket Consent filed by Petitioner, Alexandru Bittner
2022-07-19
Blanket Consent filed by Respondent, United States
2022-06-21
Petition GRANTED.
2022-06-13
DISTRIBUTED for Conference of 6/16/2022.
2022-05-24
DISTRIBUTED for Conference of 6/9/2022.
2022-05-20
Waiver of the 14-day waiting period for the distribution of the petition under Rule 15.5 filed by petitioner.
2022-05-17
Brief of respondent United States filed.
2022-04-27
Motion to extend the time to file a response is granted and the time is further extended to and including May 17, 2022.
2022-04-26
Motion to extend the time to file a response from May 2, 2022 to May 17, 2022, submitted to The Clerk.
2022-04-01
Brief amicus curiae of Center for Taxpayer Rights filed.
2022-04-01
Brief amicus curiae of American College of Tax Counsel filed.
2022-04-01
Brief amicus curiae of The Chamber of Commerce of the United States of America filed.
2022-03-24
Motion to extend the time to file a response is granted and the time is extended to and including May 2, 2022.
2022-03-23
Motion to extend the time to file a response from April 1, 2022 to May 2, 2022, submitted to The Clerk.
2022-02-28
Petition for a writ of certiorari filed. (Response due April 1, 2022)
Attorneys
Alexandru Bittner
Daniel L. Geyser — Haynes and Boone, LLP, Petitioner
American College of Tax Counsel
American College of Trust and Estate Counsel
David Edward Sloan — Fabian Vancott, Amicus
Center for Taxpayer Rights
Guinevere M. Moore — Moore Tax Law Group LLC, Amicus
National Federation of Independent Business Small Business Legal Center, National Association of Home Builders of the United States, American Farm Bureau Federation, Restaurant Law Center, and Corn Refiners Association
National Whistleblower Center
Rachel Gagnebin Talay — H Street Law PLLC, Amicus
The Chamber of Commerce of the United States of America
United States
Elizabeth B. Prelogar — Solicitor General, Respondent