1. Did the Court err in holding that Alice acted
willfully, despite the lack of proof either that she had
knowledge of the requirement to file an FBAR or of her
intent to evade taxes?

2. Did the Court's finding of willfulness despite
lack of proof of intent or knowledge improperly interpret the
statute by rendering every failure to file willful, although the
statute (31 U.S.C. §§5321) provides differing penalties for
willful and non-willful violations?

3. Did the Court err in finding that the
Respondent properly assessed the maximum penalty on the
Petitioner's foreign bank account, in light of the substantial
proof of the fact that the Respondent relied upon erroneous
findings of fact, and that the assessment of the penalty was
punitive?

4. Did the Court err in holding that Alice did not
preserve her argument that the 50% penalty imposed upon
her account was an Excessive Fine under the Eighth
Amendment to the United States Constitution?

5. Was the penalty imposed upon Alice's account
($697,229) an Excessive Fine under the Eighth Amendment
to the United States Constitution?

6. Did the Court err in finding that the
amendments to the law [31 U.S.C. §5321(a)(5)(C)()]
superseded IRS regulation [31 CFR §1010.820] regarding
the maximum penalty that can be imposed by the IRS after
a finding of a willful failure to file Foreign Bank Account
Report ("FBAR")?

Did the Court err in holding that Alice acted willfully, despite the lack of proof either that she had knowledge of the requirement to file an FBAR or of her intent to evade taxes?