Bittner v. United States

Bittner v. United States
Argued November 2, 2022
Decided February 28, 2023
Full case nameBittner v. United States
Docket no.21-1195
Citations598 U.S. 85 (more)
Holding
The penalty for non-willful failure to report a bank account under the Bank Secrecy Act applies once per failed report, not once per account.
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch · Brett Kavanaugh
Amy Coney Barrett · Ketanji Brown Jackson
Case opinions
MajorityGorsuch
DissentBarrett

Bittner v. United States, 598 U.S. 85 (2023), was a United States Supreme Court case related to the penalty for multiple failures to report a foreign bank account.[1] After the fall of communism in Romania, Alexandru Bittner, a naturalized American citizen, returned to his native country and became a businessman, but failed to report his foreign bank accounts to the Internal Revenue Service (IRS), as required by the Bank Secrecy Act. He later filed corrected reports for 2007-2011. Under statutory law, the government is authorized to fine a maximum penalty of $10,000 for non-willful failure to report a foreign bank account. Because the number of accounts over 5 years totaled 272, the government sought to fine Mr. Bittner $2.72 million. The case was notable for the resulting "strange lineup of justices" which did not split along traditional ideological lines.[2]

  1. ^ "Bittner v. United States, 598 U.S. ___ (2023)". Justia Law. Retrieved 2024-06-21.
  2. ^ "Strange lineup of justices limits penalties for failure to file reports about foreign bank accounts". SCOTUSblog. 2023-02-28. Retrieved 2024-06-21.