Statute that allows for penalties for any violation of a certain section does not permit multiple penalties for multiple aspects of the violation of a single obligation, but rather establishes that any of the violations specified in the statute and associated regulations are subject to the penalty.
Materially similar provision for willful violations of the same obligation that allows for multiple penalties cuts against the idea that multiple penalties should be allowed in the section of the statute that doesn't explicitly mention them.
Tax statutes should be strictly constructed where they impose an obligation.
DISSENT:
The reporting requirement is a procedural element, but the substance of the statute is that each of the foreign bank accounts should be reported.
The use of "violation" as defined by its context in the similar provision establishes that the term should have that definition throughout the statute.
Majority's reading is not strict, but strained.