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MUCH more likely he'll never pay a cent, just legal wrangling and when they fail to prove intent upon appeal in a couple of years, he sues the State Dept., and very likely you, for his legal expenses; it'll end with him saying, "Oops- I didn't know; I'll never do it again...I promise!" and getting a reprimand...maybe he'll just resign and retire to Florida where he can spend his pension in peace at a much lower tax rate.
The lawyers will be the only ones who get paid.
Or the Form 109's will magically appear because a bunch of firefighters are getting writer's cramp right now- be on the lookout for a lot of sick days/disability for Carpal Tunnel Syndrome...
For someone who is so smart about some things, I'm surprised you don't know how this will play out.
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