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1. The December 2012 Journal of Taxation article, Third Time's the Charm: Government Finally Collects 'Willful' FBAR Penalty in Williams authored by Hale E. Sheppard

1. The December 2012 Journal of Taxation article, "Third Time's the Charm: Government Finally Collects 'Willful' FBAR Penalty in Williams" authored by Hale E. Sheppard is a. Primary authority b. Secondary authority

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