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Huh? They have little control over filing a return and reporting foreign accounts? The one thing in the article that evoked some sympathy from me is the growing reluctance of foreign financial institutions to do business with US citizens.

What I read in the article was that many of these people had filed a return, but not a specific document that was required to accompany the return. And that it was difficult to get the institutions to provide the documents they needed to file with the return. So yes, I would call that pretty much out of their control, and I would consider the penalties for failure to include those supporting docs cruel and unusual punishment.

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