Jason B. Freeman and Matthew Roberts of Freeman Law, PLLC discuss the recent FBAR penalty case of United States v. Bittner, a recent decision from the district court for the Eastern District of Texas. The Bittner case involves non-willful FBAR penalty assessments - a penalty imposed under the Bank Secrecy Act for failing to report foreign bank accounts on a FBAR form (FinCEN 114). Jason and Matt discuss the history of the FBAR reporting requirement and break down the issues presented in the case, as well as the court's analysis.