At least in that case the appeals court tossed it. However, not due to any problem in the law, but based on the improper use of unrelated evidence.

There was a case I read about where a Russian woman who immigrated to the US (legally).

She was trying to transfer money from her bank in Russia to a US bank so she could buy a house here. The Russian bank refused to do individual transfers over $9K US.

She transferred all the money, pain fully over several months and right after she bought the house she wanted, the IRS stepped in and sized the house as the fruits of structuring.

She had all the documentation need to prove that all the money was hers and obtained legally. The IRS didn’t care.

Shouldn’t federal judges be more willing to sanction attorneys who defend this sort of nonsense? Obviously, I’d never be a federal judge, but this sort of tyranny-lite would prompt me to want to hold the government attorney and the applicable decisionmaker in contempt of court.

I suspect the quote comes from the cited source, not the Treasury report (and in fact that quote does appear in the cited source).