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Try CasePortal for FreeJ. Immergut grants the government's entry for judgment after remand for its complaint that the account holders did not file reports of Foreign Bank and Financial Accounts for their Canadian bank accounts for 2011, 2012 and 2013 and for their Iranian bank accounts for 2012 and 2013. The account holders propose an alternative exchange rate for this matter because there was a better alternative, but the IRS has full discretion on what method they want to use for accounts and reports.
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