The Subjects contend that these records are not customarily kept by foreign bank account holders who wish their accounts to remain secret. But they cite no authority for this proposition.I would have thought the contention was an obvious proposition that would not have required authority..
Readers will recall that there is pending now a petition for certiorari on the Seventh Circuit decision. Petition for Cert filed in FBAR Required Records Case (Federal Tax Crimes Blog 1/18/13), here.
The opinion is relatively short because the ground is well-traveled and new ground is not covered.
The original article informing me of this opinion is Patricia Hurtado and Christie Smythe, Grand Jury Probing Foreign Bank Accounts, U.S. Judge Says (Bloomberg 2/20/13), here.