On June 21, 2023, Caroline D. Ciraolo discusses Bedrosian v. United States with the ABA Tax Section Administrative Practice Committee.

Description: On June 20, 2023, the Supreme Court denied a petition for writ of certiorari in Bedrosian v. United States, Case No. 22-598, one of the longest running cases involving the imposition of willful civil penalties for failure to file an accurate Report of Foreign Bank and Financial Accounts (FBAR). Caroline Ciraolo will walk through the history of the Bedrosian case, starting with the relevant facts and circumstances, including the background of Mr. Bedrosian, to the administrative examination and appeal, and through the layers of litigation before the U.S. District Court for the Eastern District of Pennsylvania, the U.S. Court of Appeals for the Third Circuit, and the U.S. Supreme Court.