Bohanec

*883 FINDINGS OF FACT AND CONCLUSIONS OF LAW

Plaintiff, - United States of America, seeks to collect a civil penalty assessed to Defendants August Bohanec and Maria Bohanec (collectively, “Defendants” or “the Bohances”) for willful failure to report their interest in foreign bank accounts during tax year 2007, as required under 31 U.S.C. § 5314 and its implementing regulations. This matter was tried before the court on November 1,2016. Having considered the submissions and arguments of the parties, as well as the evidence in the record, the court hereby makes the following findings of facts and conclusions of law.

I.FINDINGS OF FACT

1. August Bohanec was born in 1933 in Slovenia.

2. August Bohanec immigrated to the United States in 1961 and became a naturalized citizen of the United States in the mid-to-late 1960s.

3. Before immigrating to the United States, August Bohanec was trained ás a tool-and-die maker.

4. Maria Bohanec was born in 1943 in Mexico.

5. Maria Bohanec immigrated to the United States in the 1960s and became a naturalized citizen of the United States in the 1990s.

6. The highest level of education Maria Bohanec has is the 6th grade in Mexico.

7. August…