United States v. Peter Horowitz

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the criminal standard for willful 21 failure to file FBARs is higher than the civil standard
• observing but not holding that “[a]ny person who fails to file an FBAR is subject to a maximum civil penalty of not more than $10,000”
• affirming willfulness where taxpayers knew they were holding significant portion of their savings in foreign bank account
• affirming summary judgment on evidence that the taxpayers set up their Finter account as a numbered account with hold mail service
• affirming summary judgment where “[d]espite numerous red flags, [the plaintiffs] neither made a simple inquiry to their accountant nor gave even the minimal effort necessary to render meaningful their sworn declaration that their tax returns were accurate.”
• “[W]e conclude that, for the purposes of applying § 5321(a)(5)’s civil penalty, a ‘willful violation’ of the FBAR reporting requirement includes both knowing and reckless violations”

Source: CourtListener parenthetical corpus (CC0).

Cited by

9 cases in this archive cite this case.

• United States v. Said Rum
  Eleventh Circuit· 2021-04-23· cited 23×
• United States v. Kahn
  Second Circuit· 2021-07-13· cited 15×
• United States v. Toth
  First Circuit· 2022-04-29· cited 15×
• Arthur Bedrosian v. IRS
  Third Circuit· 2022-07-22· cited 13×
• United States v. James Kelly, Jr.
  Sixth Circuit· 2024-02-08· cited 4×
• United States v. Timberly Hughes
  Ninth Circuit· 2024-08-21· cited 3×
• Landa v. United States
  Federal Claims· 2021-04-19
• United States v. Bittner
  Fifth Circuit· 2021-11-30
• United States v. Reyes
  Second Circuit· 2026-01-07

Cites

9 cases in this archive are cited by this case.

• Farmer v. Brennan
  Supreme Court· 1994-06-06· cited 28,443×
• Spies v. United States
  Supreme Court· 1943-01-18· cited 1,702×
• Safeco Insurance Co. of America v. Burr
  Supreme Court· 2007-06-04· cited 1,225×
• Ratzlaf v. United States
  Supreme Court· 1994-01-11· cited 1,218×
• Bryan v. United States
  Supreme Court· 1998-06-15· cited 683×
• Global-Tech Appliances, Inc. v. SEB S. A.
  Supreme Court· 2011-05-31· cited 600×
• United States v. Ibrahim Ahmed Al-Hamdi, United States of America v. Ibrahim Ahmed Al-Hamdi
  Fourth Circuit· 2004-01-23· cited 175×
• United Dominion Industries, Inc. v. United States
  Supreme Court· 2001-06-04· cited 91×
• Norman v. United States
  Federal Circuit· 2019-11-08· cited 23×