Friday, December 13, 2024

DOJ December 2023 Publication on Tax Enforcement (12/13/24)

This blog entry will alert readers of the following publication: Misc. Authors, Tax Enforcement, 71 DOJ J. Fed. Law & Prac., No. 4 (December 2023), here.

The following is a copy and paste of the Table of Contents (presented in table format). 

Tax Enforcement

Introduction

David A. Hubbert

1

Restitution in Criminal Tax Cases: Common Pitfalls and Practical Strategies

Elissa Hart-Mahan & Hannah Cook

5

Investigating Legal Source Income Tax Cases

Todd Ellinwood & Caryn Finley

23

Follow That Lead! Obtaining and Using Tax Information in a Non-Tax Case

Andrew H. Kahl

47

Tax Fraud Involving COVID-Relief Provisions

David Zisserson

63

Attorney–Client Privilege in the Context of Tax Preparation and Tax Planning  

Larry Wszalek & Stuart Wexler

79

Prosecuting Tax Obstruction Under 26 U.S.C. § 7212(a)

Gregory S. Knapp & Joseph B. Syverson

97

Sentencing Advocacy in Criminal Tax Cases—Making the Government’s Case for the Appropriate Sentence

Stanley J. Okula, Jr. & Matthew Hicks

109

A Fool for a Client: Legal and Practical Considerations When Facing Pro Se Defendants

Katie Bagley & Melissa Siskind

129

A Taxing Dilemma: Navigating the Crime–Fraud Exception in  Criminal Tax Cases

Sean Beaty & Wilson Stamm

155

Prosecuting Fraudulent Tax Return Preparers

Sarah Kiewlicz & Thomas F. Koelbl

175

Gathering and Using Foreign Evidence in Tax Cases

Kimberle E. Dodd & Nanette L. Davis

199

Monetary Claims Against the Government: When Are They Tax Refund Cases

Jason Bergmann & Richard J. Markel

223

They Don’t Make ‘Em Like They Used To: Statutory Jurisdictional Requirements in the Age of the Clear-Statement Rule

Marie E. Wicks & Michael W. May

241

Note from the Editor-in-Chief

Christian A. Fisanick

265

Although, as of today, the presentations are about a year old and there have been developments in many of the areas, still there are some real gems in the various discussions. Highly recommended for students and practitioners. As I go through the various presentations, I may post subsequent blog entries on some of the items that I think might be particularly useful for readers of this blog.