Bittner, was required to file reports under the Bank Secrecy Act (BSA). In 2004, Congress amended the law to create a penalty for the non-willful failure to file certain reports pertaining to foreign bank accounts. After filing reports, Bittner was assessed penalties for over fifty accounts that he had failed to report over several years. The Secretary of the Treasury assessed a penalty for his non-willful failure to file in the amount of $10,000 per account per year, while Bittner claimed the amount should be $10,000 per annual report. Bittner was assessed a penalty of $2.7 million. The Fifth Circuit ruled in favor of the United States. Bittner appealed. Justice Gorsuch wrote the opinion of the court reversing the Fifth Circuit, finding in favor of Bittner. Recorded by Jake Leahy. Bittner v. United StatesSupport the show