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United States v. Chabot
United States Court of Appeals for the Third Circuit
793 F.3d 338 (2015)
Eli and Renee Chabot (defendants) owned a number of foreign bank accounts. The Chabots did not disclose these accounts to the Internal Revenue Service (IRS) (plaintiff). The IRS issued summonses to the Chabots regarding their foreign accounts. The summonses requested that the Chabots appear before the IRS to give testimony and produce documents for their accounts. The Chabots refused and asserted their privilege against self-incrimination under the Fifth Amendment to the United States Constitution through their attorney. The IRS amended the summonses to include a request for the production of only the documents that are required to be maintained under 31 C.F.R. § 1010.420. Section 1010.420 required owners of foreign accounts to keep basic account information like the name on the account, account number, contact information for the bank, and account value. The Chabots refused again. The IRS filed a petition to enforce the summonses in the district court. The Chabots again invoked their Fifth Amendment privilege against self-incrimination. The district court held that the required-records exception to the Fifth Amendment applied, and it granted the petition to enforce the summonses. The Chabots appealed to the United States Court of Appeals for the Third Circuit.
Rule of Law
Holding and Reasoning (Restani, J.)
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