[1] After the fall of communism in Romania, Alexandru Bittner, a naturalized American citizen, returned to his native country and became a businessman, but failed to report his foreign bank accounts to the Internal Revenue Service (IRS), as required by the Bank Secrecy Act.

Under statutory law, the government is authorized to fine a maximum penalty of $10,000 for non-willful failure to report a foreign bank account.

Because the number of accounts over 5 years totaled 272, the government sought to fine Mr. Bittner $2.72 million.

The case was notable for the resulting "strange lineup of justices" which did not split along traditional ideological lines.

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