Records of accounts required by section1010.350 to be reported to the
Commissioner of Internal Revenue shall be retained by each person having a
financial interest in or signature or other authority over any such account.
Such records shall contain the name in which each such account is maintained,
the number or other designation of such account, the name and address of the
foreign bank or other person with whom such account is maintained, the type
of such account, and the maximum value of each such account during the
reporting period. Such records shall be retained for a period of 5 years and
shall be kept at all times available for inspection as authorized by law. In
the computation of the period of 5 years, there shall be disregarded any
period beginning with a date on which the taxpayer is indicted or information
instituted on account of the filing of a false or fraudulent Federal income
tax return or failing to file a Federal income tax return, and ending with
the date on which final disposition is made of the criminal
proceeding.