Essentially, the PTO assumed every instance in which inequitable conduct might be charged will necessarily result in a supplemental examinationrequest being submitted.
The IRS will not impose a penalty for the failure to file the delinquent FBARs if there are no underreported tax liabilities and the taxpayer has not previously been contacted regarding an income tax examination or a request for delinquent returns.
Any party can refer the case to the Grand Chamber of the European Court of Human Rights within that period and request a further examination by a five-judge panel.
Given the cost and risks inherent in any supplemental examination procedure, it is not reasonable to assume every application will be the subject of a request.