Updates for Prior Blog Postings (8/28/20)

Starting 5/4/20, I will use this page to link to blog posts that I have updated with subsequent information that I do not feel is important enough to warrant a new blog post.  The table below is in reverse chronological order of the postings.  In the title of this page, I will show the date of the last update.

 

Date

Blog Post

Update Info

8/28/20

Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 8/28/20), here

Added paragraph 12 to report the Court’s entry of order altering or amending the judgment on the Government’s motion to set the penalties at lower amounts actually assessed by Treasury.

8/14/20

A Bit of History: Andrew Mellon and Tax Fraud (8/12/20; 8/14/20)

Added comment 1 requesting information about the Mellon criminal no-bill and civil trial

8/2/20

The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 8/2/28), here

Added a discussion (par. 7) discussion a practitioner’s comments.

7/29/20

The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 7/29/28), here

Added 3 more comments (pars. 4-6) relating to the deficiency calculation for the Tax Court

7/28/20

The Unspotted Issue in an Audit; Ethics and Crimes (7/24/20; 7/28/28), here

Added 3 comments (pars. 1-2 relating to the claim for refund example and adding one related to analogous IRS conduct (par. 3)

7/17/20

Revised IRS Form 14457 for Voluntary Disclosure Preclearance (5/29/20; 7/17/20),here

Added bullet points from discussion of the Form and process from the ABA Tax Section May Civil and Criminal Tax Penalties telecast on 7/14/20.

7/12/20

New CTM discussion on § 7212(a) re Marinello (7/1/20; 7/12/20), here

Added the points I thought worth mentioning after review of the revised CTM

5/26/20

Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 5/26/20), here.

Added Comment 9 to alert readers to the Court’s holding that the FBAR willful penalty does not violate the Eighth Amendment excess fine prohibition.

5/19/20

Court Re-Calculates Willful Penalties Found to Be Arbitrary (5/18/20; 5/26/20), here.

Added (1) in comment 7 a trajectory of the taxpayer in conjunction with the history of the offshore account initiative and (2) comment 10 a discussion of the entry of judgment

5/4/20

Compassionate Release from Incarceration Based on COVID-19 Pandemic (4/20/20; 5/7/20), here

Denial of Compassionate Release for Paul Daugerdas