Bittner v. United States

Bittner v. United States
Supreme Court of the United States
Argued November 2, 2022 Decided February 28, 2023
Full case name	Bittner v. United States
Docket no.	21-1195
Citations	598 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
Majority	Gorsuch
Dissent	Barrett

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. 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.