I agree with your broader point but I’m pretty sure the Supreme Court case is about a technicality involving foreign bank account reporting, basically whether a

I agree with your broader point but I’m pretty sure the Supreme Court case is about a technicality involving foreign bank account reporting, basically whether a failure to file that you had 5 foreign bank accounts is 5 counts or 1 count of FBAR violations. Unless there’s another pending case I haven’t heard of?